U.S. GOVERNMENT PUBLISHING OFFICE

35–753 PDF WASHINGTON : 2019

S. HRG. 115–569 

THE COMMERCIAL SATELLITE INDUSTRY: 

WHAT’S UP AND WHAT’S ON THE HORIZON 

HEARING 

BEFORE THE

COMMITTEE ON COMMERCE, 

SCIENCE, AND TRANSPORTATION 

UNITED STATES SENATE 

ONE HUNDRED FIFTEENTH CONGRESS 

FIRST SESSION 

OCTOBER 25, 2017 

Printed for the use of the Committee on Commerce, Science, and Transportation 

( 

Available online: http://www.govinfo.gov 

(II) 

SENATE COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION 

ONE HUNDRED FIFTEENTH CONGRESS 

FIRST SESSION 

JOHN THUNE, South Dakota, Chairman 

ROGER F. WICKER, Mississippi 

ROY BLUNT, Missouri 

TED CRUZ, Texas 

DEB FISCHER, Nebraska 

JERRY MORAN, Kansas 

DAN SULLIVAN, Alaska 

DEAN HELLER, Nevada 

JAMES INHOFE, Oklahoma 

MIKE LEE, Utah 

RON JOHNSON, Wisconsin 

SHELLEY MOORE CAPITO, West Virginia 

CORY GARDNER, Colorado 

TODD YOUNG, Indiana 

BILL NELSON, Florida, Ranking 

MARIA CANTWELL, Washington 

AMY KLOBUCHAR, Minnesota 

RICHARD BLUMENTHAL, Connecticut 

BRIAN SCHATZ, Hawaii 

EDWARD MARKEY, Massachusetts 

CORY BOOKER, New Jersey 

TOM UDALL, New Mexico 

GARY PETERS, Michigan 

TAMMY BALDWIN, Wisconsin 

TAMMY DUCKWORTH, Illinois 

MAGGIE HASSAN, New Hampshire 

CATHERINE CORTEZ MASTO, Nevada 

NICK ROSSI, Staff Director 

ADRIAN ARNAKIS, Deputy Staff Director 

JASON VAN BEEK, General Counsel 

KIM LIPSKY, Democratic Staff Director 

CHRIS DAY, Democratic Deputy Staff Director 

RENAE BLACK, Senior Counsel 

(III) 

C O N T E N T S 

Page 

Hearing held on October 25, 2017 .......................................................................... 1 

Statement of Senator Thune ................................................................................... 1 

Prepared statement .......................................................................................... 2 

Statement of Senator Nelson .................................................................................. 3 

Statement of Senator Wicker .................................................................................. 112 

Statement of Senator Sullivan ............................................................................... 114 

Statement of Senator Cortez Masto ....................................................................... 115 

Statement of Senator Hassan ................................................................................. 117 

Statement of Senator Gardner ............................................................................... 121 

Statement of Senator Inhofe ................................................................................... 123 

Statement of Senator Peters ................................................................................... 125 

Statement of Senator Blumenthal .......................................................................... 127 

Statement of Senator Markey ................................................................................. 129 

WITNESSES

Patricia Cooper, Vice President, Satellite Government Affairs, Space Exploration Technologies Corp. (SpaceX) .................................................................... 5 

Prepared statement .......................................................................................... 7 

Mark Dankberg, Founder and Chief Executive Officer, ViaSat, Inc. .................. 17 

Prepared statement .......................................................................................... 19 

Stephen Spengler, Chief Executive Officer, Intelsat ............................................ 103 

Prepared statement .......................................................................................... 104 

Greg Wyler, Founder and Executive Chairman, WorldVu Satellites Limited 

(OneWeb) .............................................................................................................. 107 

Prepared statement .......................................................................................... 109 

APPENDIX

Response to written questions submitted by Hon. Maggie Hassan to: 

Patricia Cooper ................................................................................................. 141 

Mark Dankberg ................................................................................................. 142 

Stephen Spengler .............................................................................................. 144 

Response to written questions submitted to Greg Wyler by: 

Hon. Cory Booker ............................................................................................. 145 

Maggie Hassan ................................................................................................. 146 

(1) 

THE COMMERCIAL SATELLITE INDUSTRY: 

WHAT’S UP AND WHAT’S ON THE HORIZON 

WEDNESDAY, OCTOBER 25, 2017 

U.S. SENATE, 

COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION, 

Washington, DC. 

The Committee met, pursuant to notice, at 10:07 a.m. in room 

SR–253, Russell Senate Office Building, Hon. John Thune, Chairman of the Committee, presiding. 

Present: Senators Thune [presiding], Nelson, Wicker, Fischer, 

Sullivan, Inhofe, Johnson, Capito, Gardner, Young, Cantwell, 

Klobuchar, Blumenthal, Markey, Peters, Baldwin, Hassan, and 

Cortez Masto. 

OPENING STATEMENT OF HON. JOHN THUNE, 

U.S. SENATOR FROM SOUTH DAKOTA 

The CHAIRMAN. Good morning. Welcome to today’s hearing on 

the state of the commercial satellite industry and the promises of 

next-generation satellite technology to improve the lives of Americans. I believe we’re at a critical moment in the development of satellite capability, and I’m excited to hear from our panel of distinguished witnesses today. 

Satellite services available today offer residential broadband at 

speeds substantially greater than those available just a few years 

ago—download speeds that meet the Federal Communications 

Commission’s definition of advanced telecommunications capability, 

and in some cases, without the strict data cap limits that have 

vexed users of satellite broadband in the past. Much of our television broadcast programming is delivered to broadcasters by satellite with extraordinary reliability, and millions of Americans receive their video service through direct broadcast satellite. 

This summer, the FCC for the first time authorized access to the 

U.S. market to a provider using a proposed constellation of 720 satellites. OneWeb received approval to enter the U.S. market with an 

array of satellites to provide global, high-speed broadband, including in remote and hard-to-serve areas. For comparison, there are 

about 1,000 satellites total in operation today. This new type of 

service would place satellites in a much lower orbit than many of 

the satellites currently in operation. 

Similarly, SpaceX seeks to bring its satellite expertise to bear 

with a proposal to deploy a constellation of thousands of satellites 

to provide high-speed broadband. If realized, these ambitious proposals could completely change consumer access to broadband in 

2 

rural areas as well as cities across the country and around the 

world. 

Satellite capability can also play a critical role in establishing 

communication after natural disasters, and it has been used by the 

Red Cross and others as part of the effort to reconnect the residents of Puerto Rico after the devastation caused by Hurricane 

Maria, as well as those affected by hurricanes in Texas and Florida. 

As with the wireless services this Committee has examined at 

numerous hearings, spectrum is critical to satellite services. As the 

value of spectrum has skyrocketed with America’s increasing demand for broadband, spectrum that previously had little value for 

mobile broadband use now faces competing demands. 

It is essential that any evaluation of these competing demands 

accurately consider the full range of spectrum uses and how best 

to deliver broadband and other services to the American people. 

The specifics of how to balance such demands in the public interest—things like allocating spectrum between services and between 

licensed and unlicensed use; setting appropriate interference levels 

between terrestrial and satellite uses; and determining the size, 

number, and location of exclusions zones—are as important as they 

are complex. However, they are not the subject of today’s hearing, 

as the FCC is addressing those matters in the ongoing Spectrum 

Frontiers proceeding and elsewhere. 

But it is important to set the broad parameters of this discussion. We must ensure that next-generation technologies rise or fall 

on their merits, including their efficiency in the use of spectrum, 

and ultimately their ability to meet the demands of American 

households for reliable high-speed broadband. 

Today we will have an opportunity to hear from some of the leaders and innovators in the field who are redefining satellite capability and who can explain what satellite services can offer to ongoing efforts to make broadband more available to all parts of the 

country and the world. 

Wireline service, fixed and mobile wireless service, and satellite 

service all have a role to play in connecting Americans to next-generation broadband service. 

Understanding satellite capability and the potential of next-generation satellite deployments will help inform this Committee regarding the costs and benefits of spectrum allocations, spectrum 

sharing, and related technology-neutral policies, among other 

things. 

So I am pleased that we have such a distinguished panel to address these matters today, and I look forward to hearing their 

thoughts. 

[The prepared statement of Senator Thune follows:] 

PREPARED STATEMENT OF HON. JOHN THUNE, U.S. SENATOR FROM SOUTH DAKOTA

Good morning. Welcome to today’s hearing on the state of the commercial satellite 

industry and the promises of next-generation satellite technology to improve the 

lives of Americans. I believe we are at a critical moment in the development of satellite capability, and I am excited to hear from our panel of distinguished witnesses 

today. 

Satellite services available today offer residential broadband at speeds substantially greater than those available just a few years ago—download speeds that meet 

3 

the Federal Communications Commission’s definition of ‘‘advanced telecommunications capability’’—and in some cases without the strict data cap limits that had 

vexed users of satellite broadband in the past. Much of our television broadcast programming is delivered to broadcasters by satellite with extraordinary reliability, 

and millions of Americans receive their video service through direct broadcast satellite. 

This summer, the FCC for the first time authorized access to the U.S. market to 

a provider using a proposed constellation of 720 satellites. OneWeb received approval to enter the U.S. market with an array of satellites to provide global, highspeed broadband, including in remote and hard-to-serve areas. For comparison, 

there are about 1000 satellites total in operation today. This new type of service 

would place satellites in a much lower orbit than many of the satellites currently 

in operation. Similarly, SpaceX seeks to bring its satellite expertise to bear with a 

proposal to deploy a constellation of thousands of satellites to provide high-speed 

broadband. If realized, these ambitious proposals could completely change consumer 

access to broadband in rural areas as well as cities across the country and around 

the world. 

Satellite capability can also play a critical role in establishing communication 

after natural disasters, and has been used by the Red Cross and others as part of 

the effort to reconnect the residents of Puerto Rico after the devastation caused by 

Hurricane Maria, as well as those affected by hurricanes in Texas and Florida. 

As with the wireless services this Committee has examined at numerous hearings, 

spectrum is critical to satellite services. As the value of spectrum has skyrocketed 

with America’s increasing demand for broadband, spectrum that previously had little value for mobile broadband use now faces competing demands. 

It is essential that any evaluation of these competing demands accurately consider 

the full range of spectrum uses and how best to deliver broadband and other services to the American people. The specifics of how to balance such demands in the 

public interest—things like allocating spectrum between services and between licensed and unlicensed use; setting appropriate interference levels between terrestrial and satellite uses; and determining the size, number, and location of exclusion 

zones—are as important as they are complex. However, they are not the subject of 

today’s hearing as the FCC is addressing those matters in the ongoing Spectrum 

Frontiers proceeding and elsewhere. 

But it is important to set the broad parameters of this discussion. We must ensure that next-generation technologies rise or fall on their merits, including their 

efficiency in the use of spectrum, and ultimately their ability to meet the demands 

of American households for reliable, high-speed broadband. 

Today we will have an opportunity to hear from some of the leaders and 

innovators in the field who are redefining satellite capability and who can explain 

what satellite services can offer to ongoing efforts to make broadband more available to all parts of the country and the world. Wireline service, fixed and mobile 

wireless service, and satellite service all have a role to play in connecting Americans 

to next-generation broadband service. 

Understanding satellite capability and the potential of next-generation satellite 

deployments will help inform this Committee regarding the costs and benefits of 

spectrum allocations, spectrum sharing, and related technology-neutral policies, 

among other things. I am pleased that we have such a distinguished panel to address these matters today, and look forward to hearing their thoughts. 

The CHAIRMAN. And I recognize Senator Nelson for his opening 

statement. 

STATEMENT OF HON. BILL NELSON, 

U.S. SENATOR FROM FLORIDA 

Senator NELSON. Thank you, Mr. Chairman. 

Well, this is an exciting time because communications satellites 

are essential links in our globally connected world. They bounce 

television signals all over the planet and provide voice communication and Internet access to remote areas. And in a recognition of 

satellites’ resiliency and reliability, first responders and those in 

disaster areas, like Florida after a hurricane, Texas, Puerto Rico, 

the Virgin Islands, they rely on satellite systems as their lifeline 

when other communications systems are down. 

4 

So the next generation of satellite-based communications systems 

holds even more promise. Large constellations, thousands of satellites, will provide broadband communications that rival the terrestrial counterparts, and it’s going to make access even more affordable for broadband Internet. It’s going to become a reality that 

broadband Internet in rural areas and remote areas that the terrestrial networks don’t reach. Other constellations promise imaging 

services that could advance key Earth and climate science initiatives. And that’s just the beginning of it. 

Much of this new interest and investment in space is coming 

from the private sector. In fact, some have begun to call this the 

second great Space Age. And as it was for the first great Space 

Age, the epicenter—and I hate to be parochial here—the epicenter—— 

[Laughter.] 

Senator NELSON.—is going to be the Cape. So goes—— 

Senator CANTWELL. [Clears throat.] 

Senator NELSON. So goes—well, we’ll let you do all your manufacturing out there—— 

[Laughter.] 

Senator CANTWELL. We’ll take—we’ll take it, we’ll take it. 

Senator NELSON.—Senator Cantwell. 

But as it was in the first great Space Age, so it now is in the 

commercial launch business. And thanks in no small part to the efforts of some of the companies here today and to our commitment 

to an ambitious civil and national security space program, the Cape 

is coming alive. The space industry has brought millions of dollars 

of investment to this country, along with thousands and thousands 

of jobs, lots of economic benefits, and a lot of spin-offs from the 

technology that is developed for the space program. 

And so as we have been working with NASA, the FAA, and the 

Air Force, and our colleagues here in Congress, we are paving the 

way to a dramatic increase in commercial space activity at the 

Cape. And when I say ‘‘the Cape,’’ that’s the generic term, not just 

the physical Cape Canaveral, which is the Air Force station, but 

it also includes the Kennedy Space Center and the commercial activities that are going on there, which are very significant. 

So take, for example, the commanding general of the 45th Space 

Wing, General Monteith, he told me recently that they now have 

the capability of supporting two launches in one day. Now, in the 

past, that could have never happened. In large part, that, in fact, 

is due to the autonomous destruct, and you don’t have to have an 

Air Force lieutenant sticking there with his finger on the destruct 

button, but you have the autonomous destruct if a rocket were to 

go off the trajectory that it’s supposed to be on, threatening populated areas. 

And over the coming years, these launches are going to be able 

to deliver thousands of new satellites to orbit, cargo and crews to 

the International Space Station, and eventually new technologies, 

like in-space manufacturing. And on top of all that, we are building 

the vehicles that will return humanity to deep space. And, ladies 

and gentlemen, we’re going to Mars, and the beginning of that is 

in 2 years with the launch of the largest rocket, most powerful 

5 

rocket ever, the SLS with its spacecraft Orion. And that’s just 2 

years away. 

So suffice it to say this, in fact, is not only an exciting time, it’s 

a critical time, for the space program and space commercialization 

as well. And that’s why it’s such an important time to have our 

space agency led by an experienced and competent professional. 

The agency has not faced this critical of an inflection point since 

the Apollo program. If we stumble now, the impacts of our civil, 

commercial, and national space capabilities could be felt for decades to come. 

And I want to thank the witnesses for being here. This is going 

to be an exciting discussion. 

Thank you, Mr. Chairman. 

The CHAIRMAN. Thank you, Senator Nelson. And we have lots of 

wide open space and uncongested air space in South Dakota, 

too—— 

[Laughter.] 

The CHAIRMAN.—so if you want to bring any of that technology 

our way, we welcome it. 

We have a great panel, as you pointed out today. We have Ms. 

Patricia Cooper, who is the Vice President of Satellite Government 

Affairs at SpaceX; Mr. Mark Dankberg, who is the Chief Executive 

Officer of ViaSat; Mr. Stephen Spengler, who is the CEO of 

Intelsat; and Mr. Greg Wyler, who is the Founder and Executive 

Chairman of OneWeb. 

So thank you all for being here. We’ll start on my left, and your 

right, with Ms. Cooper, and then proceed. And if you would all, if 

you can, limit your oral remarks to about 5 minutes, it will give 

us optimum time to ask questions. And we’ll make sure that all of 

your remarks get made part of the written record of this hearing. 

So thank you for being here. 

Ms. Cooper. 

STATEMENT OF PATRICIA COOPER, VICE PRESIDENT, 

SATELLITE GOVERNMENT AFFAIRS, 

SPACE EXPLORATION TECHNOLOGIES CORP. (SPACEX) 

Ms. COOPER. Mr. Chairman, Ranking Member Nelson, and members of the Committee, I am pleased to be back today representing 

SpaceX and my more than 6,000 colleagues who are revolutionizing 

space technologies. Mr. Chairman, there’s a space renaissance underway, and SpaceX is proud to be at the forefront of innovation. 

My testimony today will outline SpaceX’s plans to harness the 

platform of space for a new approach to broadband delivery. I will 

also recommend actions that the Committee can take to foster innovation, by streamlining regulations, driving efficient spectrum 

use, and protecting the safety of space. 

SpaceX is designing, developing, building, and launching a constellation of over 4,000 satellites operating close to the Earth. We 

have designed our constellation to achieve an ambitious and compelling goal, connecting the hundreds of millions of Americans and 

billions of global citizens to high-speed broadband. 

Our direct-to-consumer focus drives the large scale of our system, 

featuring substantial on-orbit capacity and to keep pace as 

6 

broadband demand grows, and sophisticated techniques for frequency reuse. 

From the outset, our constellation planning aimed to push the 

edge of innovation so that we can groom our coverage to match the 

peaks and valleys of broadband demand, interoperate flexibly with 

other users, and protect the space environment. Underlying these 

plans are the credentials that SpaceX has built over 15 years that 

demonstrate our capability to manufacture and operate complex 

space systems with unprecedented innovation, efficiency, scale, and 

affordability. 

Unlike many other aerospace firms, SpaceX is heavily vertically 

integrated. We build our Falcon rockets and our Dragon spacecraft 

in-house from tip to toe, including propulsion systems, structures, 

avionics, and launch, all within the U.S. 

Our space and launch heritage and our drive to innovate gives 

us a distinct edge in deploying our ambitious satellite project. 

SpaceX has successfully launched 42 flights of the Falcon 9, including 15 this year alone, landed 18 first stages and reused 3, and 

flown 13 supply missions to the International Space Station using 

our Dragon spacecraft. We will bring this experience to bear in our 

satellite project. 

In space, our constellation will use dynamic antennas and optical 

links between the satellites to form an efficient mesh network. 

These advancements will allow us to reuse frequencies many times 

over to ultimately deliver far greater broadband capacity to consumers. As a company, we are deeply committed to maintaining a 

debris-free environment in space, and our satellite system has been 

thoughtfully designed to meet or exceed all existing requirements 

for safety of operations in space and upon deorbit. 

On the ground, we are producing affordable, easy-to-install end 

user terminals that all but remove the incremental cost of new 

users joining our network. Here we avoid the dollars-per-mile terrestrial build-out costs and other obstacles that have made terrestrial broadband connections cost prohibitive for so many American 

communities. 

The coming low-orbiting constellations hold enormous potential 

to finally bring broadband connectivity to all corners of America at 

speeds and latencies that today are available really only in the 

most populated areas. 

Mr. Chairman, we lay out an ambitious goal, and we could use 

the Committee’s help. To summarize my written statement, we 

urge the Committee to continue its work to modernize the regulatory framework for commercial launch operations, both at the 

FAA and at the FCC. Launch is the critical path to deploying satellite constellations, and licensing rules and spectrum allocations 

must be updated to reflect that new pace and number of launches. 

SpaceX is proud to launch our constellation from U.S. soil on American-made SpaceX rockets. 

The Committee should endorse rules that foster spectrum sharing and technology advancement to make the best use of the airwaves. The FCC has already taken an important step by updating 

its rules for such satellite constellations, rightfully expecting operators to negotiate among themselves for spectrum sharing. Unfortunately, not all operators have chosen to invest in available techVerDate Nov 24 2008 13:09 Mar 27, 2019 Jkt 000000 PO 00000 Frm 00010 Fmt 6633 Sfmt 6601 S:\GPO\DOCS\35753.TXT JACKIE
7 

nologies for spectrum efficiency. The Committee has an important 

oversight function to ensure that the rules of the road incentivize 

and support smart technology that can interoperate with other 

users on orbit and on the ground. 

To protect the space environment, the Committee should encourage closer coordination among the many Federal agencies responsible for orbital safety policies and regulation. Congress should also 

consider additional investments in the Nation’s infrastructure to 

track orbital objects even more precisely. 

Finally, we ask for the Committee’s vigilance to assure tech neutrality in any and all legislation or Federal programs designed to 

expand broadband infrastructure. Blanket exclusions of any qualifying technology from existing programs, like the Connect America 

Fund, should be rescinded so that new satellite constellations can 

be harnessed for high-quality broadband connectivity in every corner of America. 

This is an exciting and dynamic time in the satellite industry. I 

thank the Committee for the opportunity to be here today and look 

forward to any questions. 

Thank you. 

[The prepared statement of Ms. Cooper follows:] 

PREPARED STATEMENT OF PATRICIA COOPER, VICE PRESIDENT, SATELLITE

GOVERNMENT AFFAIRS, SPACE EXPLORATION TECHNOLOGIES CORP. (SPACEX) 

Mr. Chairman, Ranking Member Nelson, and Members of the Committee: 

Thank you for the opportunity to participate in today’s hearing. We appreciate the 

Committee’s interest in exploring how advanced satellite technologies can expand 

broadband access within the United States and the policies that would foster that 

capability. SpaceX also appreciates that the Committee recognizes the potential of 

a new generation of U.S.-based low-Earth orbit (‘‘LEO’’) or non-geostationary satellite orbit (‘‘NGSO’’) satellite broadband system as an integral part of any strategy 

to augment high-speed Internet connectivity nationwide. NGSO satellite constellations intend to leverage emerging technologies in space and on the ground to provide reliable, high-speed, and affordable broadband service to customers throughout 

the United States and abroad. 

SpaceX was founded in 2002 with the express goal of dramatically improving the 

reliability, safety, and affordability of space transportation. Today, SpaceX today is 

the world’s largest launch services provider, measured by missions under contract 

and cadence of launch, with 42 successful Falcon 9 launches, including 15 in 2017 

alone. 

SpaceX has deployed over 65 commercial communications satellites since 2010. In 

addition to commercial satellite operators, SpaceX supports a diverse and growing 

set of satellite and space customers, including NASA, the Department of Defense, 

and allied international governments. We have signed contracts for nearly 70 missions on manifest, representing more than $10 billion. Under one of the most successful public-private programs ever undertaken with NASA, SpaceX also supports 

the Nation’s civil space program through routine cargo resupply missions with our 

Dragon spacecraft to the International Space Station (ISS). Next year, we will have 

the awesome responsibility of launching NASA astronauts to space from U.S. soil 

for the first time since the Space Shuttle was retired in 2011. SpaceX is also a certified provider to the Department of Defense for national security space launch. 

Leveraging our experience in space launch system and spacecraft design, development, production, and on-orbit operations, SpaceX is developing an innovative 

NGSO constellation. Our system is designed to reach directly to end users, and provide global broadband services at speeds, latencies and prices on par with terrestrial 

alternatives available in metropolitan communities. Accordingly, we filed applications with the Federal Communications Commission (‘‘FCC’’) in November 2016 and 

April 2017 that detail those plans. 

My testimony today will describe SpaceX’s planned satellite constellation, including our capabilities and timelines, as well as offer a number of recommendations 

for the Committee’s consideration to streamline regulatory processes, maximize 

8 

planned government investment to accelerate broadband deployment, and ensure a 

safe, collaborative operating environment in space. Specifically, my testimony today 

will focus on the following areas: 

(1) Launch. The importance of low cost launch enabled by rapid reusability and 

robust launch infrastructure to making large-scale, space-based broadband 

Internet services more viable today than ever before, and recommendations to 

improve the launch licensing regulatory framework both at the FCC and the 

Federal Aviation Administration (FAA); 

(2) Spectrum Efficiency. Recommendations to ensure the efficient use of spectrum, 

including potential regulatory incentives for systems that invest in technologies that effectively share spectrum. The Committee should take proactive 

steps to encourage and reward companies that utilize and advance technologies that result in maximum spectrum sharing and efficiency. 

(3) Technology-Neutral Programs. The need to update eligibility requirements for 

nationwide broadband infrastructure initiatives to ensure they are truly technology neutral, and do not needlessly preclude satellite systems with equivalent or better service from competing against more traditional broadband providers. This hearing is an important forum to review how satellite broadband 

has improved and can contribute to the Nation’s connectivity goals, and how 

to incorporate such services into any national infrastructure initiative. 

(4) Space Safety. The importance of ensuring that large satellite constellations 

will employ robust orbital debris and space safety protocols, including high reliability for individual spacecraft; the speedy, planned deorbit of satellites at 

the end of the useful life; the ability to implement active collision avoidance 

throughout a satellite’s life; and transparency and information sharing. 

Vertically Integrated Approach to Manufacturing and Extensive Space 

Operations Experience 

As the leading domestic commercial space launch provider, SpaceX has restored 

the U.S. as a leader in global commercial satellite launch by percentage of market 

share. In developing its fleet of highly-reliable, affordable, and innovative launch vehicle systems, SpaceX has invested billions of private capital in sophisticated manufacturing processes, engineering and design know-how for space and launch systems, the infrastructure needed to launch satellite payloads into orbit, and technologies to make launch more affordable. These manufacturing, engineering and design capabilities are trusted by the U.S. civil and national security space community, commercial satellite operators, and international governments. 

Looking forward, SpaceX intends to leverage its fifteen years of experience in 

space to develop and deploy a cost-effective and sophisticated broadband satellite 

constellation. Our vertically-integrated approach to this initiative—linking design, 

development, production, launch, and operations—lends a unique capability to address the challenges that stymied past generations that have considered low-earth 

orbiting communications constellations from space. 

SpaceX’s proven core competency is the manufacturing of complex space systems 

with increased efficiency, scale, and affordability. Here, SpaceX has a vertically-integrated approach to manufacturing uncommon within the aerospace industry. For 

Falcon, SpaceX manufactures over 70 percent of the value of the Falcon 9 in-house, 

including the first-and second-stage propulsion systems (Merlin 1D and MVacD), the 

tanks, composite structures, payload fairings, avionics, etc. Similarly, SpaceX produces the autonomous Dragon spacecraft in house, including the on-board propulsion systems (Draco and SuperDraco), pressure vessel, avionics, and all other major 

subsystems and components. SpaceX also has extensive test facilities at our Rocket 

Development facility in McGregor, Texas. 

SpaceX will carry this vertical approach to design, manufacturing, and test into 

our satellite broadband constellation. SpaceX expects to manufacture in-house the 

majority of each spacecraft, leveraging the experience we have gained with Falcon 

and Dragon in manufacturing and specific systems, such as propulsion systems, avionics, and solar arrays, among others. We are uniquely positioned to apply these 

proven methods of reliability and cost-effectiveness to our planned broadband satellite constellation. 

SpaceX’s satellite constellation will also benefit from the company’s extensive 

space operations experience, drawn from the Falcon 9 launch vehicle’s 42 successful 

flights, 18 successful fist-stage re-entries and landings, and over 13 Dragon flights 

to and from the International Space Station (ISS). SpaceX can build upon the optimized guidance, navigation, and control (‘‘GNC’’) systems that allow us to land our 

first-stage boosters on land and at sea with pinpoint accuracy. Similarly, our deep 

experience with orderly and safe de-orbit through routine Dragon missions to the 

9 

1 Cisco Visual Networking Index: Forecast and Methodology, 2015–2020, at 1 (June 6, 2016), 

available at http://www.cisco.com/c/en/us/solutions/collateral/service-provider/visual-networking-index-vni/complete-white-paper-c11–481360.pdf; see also http://blogs.cisco.com/sp/ 

happy-zettabyte-day-2016. To fathom the volume of a zettabyte, if one byte is a litter, then a 

zettabyte is the equivalent of 7080 Pacific Oceans. See id. 2 Ibid. 

3Federal Communications Commission, 2016 Broadband Progress Report, (January 28, 2016), 

GN Docket No. 15–191, available at https://apps.fcc.gov/edocs_public/attachmatch/FCC–16– 

6A1.pdf. 4 Ibid. 

5 Ibid. 

6FCC, 2016 Broadband Progress Report. 7 Ibid. 

8 Broadband Commission for Sustainable Development, ‘‘Open Statement from the Broadband 

Commission for Sustainable Development to the UN High-Level Political Forum (HLPF)’’ 

Continued 

ISS has informed and enriched careful and detailed on-orbit operations and de-orbit 

planning for the satellite constellation. SpaceX is also drawing on the operational 

experience it has built with every Federal agency working on space-related issues— 

including FCC, FAA, NASA and DOD—to prepare and coordinate for the satellite 

constellation undertaking. This unique manufacturing, operational, and cross-agency engagement will advance the planning and operations of the satellite broadband 

constellation. 

II. Expanding Broadband Access and Bridging the Digital Divide 

SpaceX sees a robust market of continuously-growing demand for high-speed 

broadband both in the United States and worldwide. Connected consumers continue 

to increase requirements for speed, capacity, and reliability. And the volume of traffic flowing over the world’s networks continues to skyrocket, with one vendor estimating that annual global Internet Protocol (‘‘IP’’) traffic surpassed the zettabyte 

threshold in 2016—meaning that over 1,000 billion gigabytes of data was exchanged 

worldwide last year.1 By 2020, that figure is projected to more than double (reaching a level nearly 100 times greater than the global IP traffic in 2005), global fixed 

broadband speeds will nearly double, and the number of devices connected to IP networks will be three times as high as the global population.2

However, as the Committee is aware, millions of Americans outside of limited 

urban areas lack basic, reliable access to broadband—even as worldwide demand for 

data skyrockets. We note a few important facts about the availability and quality 

of broadband access in the United States and worldwide: 

— According to the FCC, 34 million Americans lack access to 25 megabits per 

second (‘‘Mbps’’) broadband service, and 47 percent of the Nation’s students 

lack the connectivity to meet the FCC’s short-term goal of 100 Mbps per 1,000 

students and staff. 3

— The FCC has further noted that ‘‘there continues to be a significant disparity 

of access to advanced telecommunications capability across America with more 

than 39 percent of Americans living in rural areas lacking access to advanced 

telecommunications capability, as compared to 4 percent of Americans living 

in urban areas.’’ 4

— Connectivity levels are even lower for tribal communities, with ‘‘approximately 

41 percent of Americans living on Tribal lands lacking access to advanced telecommunications capability.’’ 5

— In addition, nearly 10 million Americans living in non-rural areas also lack 

basic access to high-speed Internet service. As a general matter, the U.S. continues to lag behind other developed nations in both its broadband speed and 

in price competitiveness. 

— Even in urban areas of the United States, a majority of Americans lacks more 

than a single fixed broadband provider from which to choose and may seek additional competitive options for high-speed service.6 According to the FCC, 

‘‘only 38 percent of Americans have more than one choice of providers for fixed 

advanced telecommunications capability,’’ with only ‘‘13 percent of Americans 

living in rural areas having more than one choice of providers of these services 

compared to 44 percent of Americans living in urban areas.’’ 7

— Beyond the United States, the United Nations Broadband Commission for Sustainable Development recently noted that 4.2 billion people, or 57 percent of 

the world’s population, are simply ‘‘offline’’ for a wide range of reasons—but 

predominately because the necessary connectivity is not present or not affordable.8

10 

(July 11, 2016), available at http://broadbandcommission.org/Documents/publications/HLPFJuly2016.pdf. 9 Update to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and 

Related Matters, IB Docket No. 16–408, Report and Order and Further Notice of Proposed Rulemaking, FCC 17–122 (rel. Sept. 27, 2017) (‘‘NGSO Report & Order’’). 10 Id., Statement of Chairman Ajit Pai (stating that he has circulated to the Commissioners 

orders granting U.S. market access to two more NGSO systems). 11 NGSO Report and Order, Statement of Chairman Ajit Pai. 12 Id., Statement of Commissioner Mignon L. Clyburn. 

III. NGSO Satellite Constellations Offer Unique Advantages in Expanding 

Broadband Access 

Satellites have traditionally served at the forefront of remote and rural 

connectivity, and often have helped to alleviate inequities in the availability of communications services, in part due to geographic reach. Historically, satellites first 

revolutionized the availability of international telephony, then pioneered global distribution of video content. More recently, satellite systems have introduced 

broadband connectivity for mobile platforms, such as aircraft and ships—establishing and supporting new markets and enhancing those businesses and their customer experience. 

New constellations of sophisticated satellites operating close to the Earth add important prospects for remote connectivity, particularly where latency is critical. In 

adopting new rules for such NGSO systems and moving briskly on NGSO applications for U.S. market access and systems licenses, the Commission has underscored 

the vital role that NGSO systems can have for the broadband landscape of the future, and that this future is coming imminently.9

At its Open Meeting on September 26, 2017, the Commission adopted a Report 

and Order and Further Notice of Proposed Rulemaking removing ‘‘regulatory obstacles for companies proposing to provide [broadband] services via large, ambitious, 

non-geostationary-satellite orbit (NGSO), fixed satellite service (FSS) systems.’’ 10

SpaceX supports the Commission’s actions in this proceeding that update outdated 

NGSO rules, create greater regulatory certainty and add flexibility for next-generation NGSO systems that hold the promise of truly nationwide satellite broadband 

coverage at speeds and latencies comparable to terrestrial fiber-optics. Chairman 

Pai recognized the importance of NGSO systems, stating that ‘‘[a]s we strive to close 

the digital divide, we must be open to any and every technology that could connect 

consumers across the country.. . . The rules we adopt will promote the next generation of NGSO systems, which could expand broadband access where it’s needed 

most.’’ 11 Commissioner Clyburn similarly stated that ‘‘[t]oday, we take yet another 

step to close those gaping divides by updating and streamlining rules to facilitate 

the deployment of NGSO FSS systems, which have the potential to provide ubiquitous broadband services to all of our communities.’’ 12

SpaceX is unique in designing its system specifically to link consumers directly 

with high-speed, low-latency broadband connectivity. On orbit, SpaceX is employing 

advanced operational techniques and spacecraft technologies in order to maximize 

the capacity it can employ for high-speed broadband services, including high-degrees 

of re-use of valuable spectrum, and flexibility in interference mitigation, allowing 

our system to co-exist with other space-and ground-based systems. On the ground, 

affordable, easy-to-install end-user terminals can obviate the costs, environmental 

regulations, property rights issues, and other regulatory obstacles, that have precluded many unconnected end-users in smaller communities, or remote locations 

from comparable quality Internet access. Once the satellite capability is deployed 

on-orbit, the incremental costs of delivering broadband access to each new customer 

become agnostic to urban, suburban, or rural locations, in contrast to traditional terrestrial broadband networks. 

SpaceX’s constellation is designed fulfill its primary service objective of providing 

high-speed broadband directly to end users globally, both widely-dispersed locations 

and also more concentrated population areas with higher capacity demands. With 

many satellites in view, the constellation offers a diversity of path for reliability and 

also access for any given customer location, even those blocked from traditional satellite services by buildings, mountains, or other physical obstacles. Phased-array 

technology on-orbit and on-ground gateways and end-user terminals permit a large 

number of very narrow beams, reusing frequencies many times over to generate a 

level of capacity that can meaningfully bridge the broadband connectivity gap. The 

same phased array technology allows for dynamic beam formation, shaping, and direction, both to tailor capacity by demand profile and also to mitigate interference 

to space-and ground-systems. Spectrum sharing prospects with terrestrial systems 

sharing the same frequency bands are enhanced by the use of high-elevation angles 

11 

13 U.S. Government Accountability Office, Rural Broadband Deployment: Improved Consistency with Leading Practices Could Enhance Management of Loan and Grant Programs, (April 

2017), GAO–17–301, available at http://www.gao.gov/assets/690/684093.pdf. 14Space Exploration Holdings, LLC, Application for Approval for Orbital Deployment and Operation Authority for the SpaceX NGSO Satellite System (November 15, 2016), Before the Federal Communications Commission, IBFS File No. SAT–LOA–20161115–00118. 15Space Exploration Holdings, LLC, Application for Approval for Orbital Deployment and Operating Authority for the SpaceX NGSO Satellite System (March 1, 2017), Before the Federal 

Communications Commission, IBFS File No. SAT–LOA–20170301–00027. 

for communications with earth stations and highly directional space station and 

earth station beams. 

The combination of unique vertically-integrated manufacturing and design capabilities, proven production and operations experience, and highly-adaptable, leadingedge technology in space and on the ground gives promise for the SpaceX constellation to help close the digital divide, and bridge the current disparity in service between well-covered metropolitan consumers and their counterparts in rural or other 

‘‘hard-to-reach’’ areas. Importantly, that urban-rural parity can also be sustained 

over future generational upgrades over the NGSO constellation, without requiring 

additional costly last-mile infrastructure upgrades. 

This lag was noted by the Government Accountability Office (‘‘GAO’’): 

Access to affordable broadband telecommunications is vital to economic growth 

and improved quality of life across the country. In rural areas in particular, 

broadband can serve to reduce the isolation of remote communities and individuals. The provision of broadband Internet infrastructure and services in the 

United States is generally privately financed. However, rural areas can have attributes that increase the cost of broadband deployment, such as remote areas 

with challenging terrain, or make it difficult to recoup deployment costs, such 

as relatively low population densities or incomes. These attributes can decrease 

the likelihood that a broadband service provider will build out or maintain a 

network in a rural area. For these reasons, some rural areas lag behind urban 

and suburban areas in broadband deployment or service speed.13

Next-generation satellite systems operating in orbits close to the Earth, powered 

by innovative technologies to provide rapid data rates and minimal latency, can 

offer a way around this gap in broadband access in the United States. 

IV. SpaceX’s Proposed Satellite Constellation Architecture 

As noted, SpaceX plans to leverage its unique space-based design, manufacturing, 

launch, and space operations experience for the planned NGSO constellation. 

In particular, SpaceX aims to apply our experience in designing and manufacturing cutting-edge space to apply technology advancements like dynamic beam 

forming and phased array antennas in space and on the ground. These will ensure 

both unparalleled frequency re-use and spectral efficiency, as well as redundant and 

high-capacity infrastructure. The satellites’ optical inter-satellite links will establish 

a ‘‘mesh network’’ in space through which the satellites will communicate with each 

other, further enhancing the capacity levels and network flexibility for faster and 

reliable broadband satellite service. 

SpaceX’s consumer focus sets it apart from most other proposed NGSO system. 

SpaceX has designed its system with the primary purpose of providing broadband 

service directly to end-users, particularly individual households and small businesses. Meeting this distinct direct-to-end-user goal demands far more on-orbit capacity, which in turn drives the larger number of satellites in the design and the 

focus on spectrum re-use efficiency. Initially, the SpaceX system will consist of 4,425 

satellites operating in 83 orbital planes (at altitudes ranging from 1,110 km to 1,325 

km). This system will also require associated ground control facilities, gateway 

earth stations, and end user earth stations.14 Using Ka-and Ku-Band spectrum, the 

initial system is designed to provide a wide range of broadband and communications 

services for residential, commercial, institutional, governmental, and professional 

users worldwide. SpaceX has separately filed for authority to operate in the V-Band, 

where we have proposed an additional constellation of 7,500 satellites even closer 

to Earth, our Very Low Earth Orbit, or ‘‘VLEO,’’ system. In the future, these satellites will provide additional broadband capacity to the SpaceX system and further 

reduce latency where populations are heavily concentrated.15

To implement the system, SpaceX will utilize powerful computing and software 

capabilities, which will enable SpaceX to allocate broadband resources in real time, 

placing capacity where it is most needed and directing energy away from areas 

where it might cause interference to other systems, either in space or on the ground. 

Because the satellites will beam directly to gateways or user terminals, the infraVerDate Nov 24 2008 13:09 Mar 27, 2019 Jkt 000000 PO 00000 Frm 00015 Fmt 6633 Sfmt 6621 S:\GPO\DOCS\35753.TXT JACKIE
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structure needed on the ground—particularly in rural or remote areas—is substantially reduced, essentially addressing the ‘‘last mile’’ challenge and helping to close 

the digital divide. In other words, the common challenges associated with siting, 

digging trenches, laying fiber, and dealing with property rights are materially alleviated through a space-based broadband network. 

SpaceX intends to continually iterate and improve the technology in the system, 

something that our satellite manufacturing cost profile and in-house launch capability uniquely enables. The ability to modify service as necessary, as well as refresh 

the technology of the satellite system through iterative spacecraft design changes 

and phased, continuous deployment, is critical to meet rapidly changing customer 

demands and responsibly utilize spectrum. This approach will ensure that the system remains adaptable to existing and future customer demands. 

For the end consumer, SpaceX user terminals—essentially, a small flat panel, 

roughly the size of a laptop—will use similar phased array technologies to allow for 

highly directive, steered antenna beams that track the system’s low-Earth orbit satellites. In space, the satellites will communicate with each other using optical intersatellite links, in effect creating a ‘‘mesh network’’ flying overhead that will enable 

seamless network management and continuity of service. The inter-satellite links 

will further help SpaceX comply with national and international rules associated 

with spectrum sharing, which distinguishes our system from some of the other proposed NGSO constellations. 

Overall, SpaceX has designed our system to achieve the following key objectives: 

(1) Capacity. By combining the umbrella coverage of the LEO Constellation with 

the more intensive coverage from the VLEO Constellation, the SpaceX System 

will be able to provide high volume broadband capacity over a wide area. 

SpaceX will periodically improve the satellites over the course of the multiyear deployment of the system, which may further increase capacity. 

(2) Adaptability. The system leverages phased array technology to steer dynamically a large pool of beams to focus capacity where it is needed. As noted, optical inter-satellite links will permit flexible routing of traffic on-orbit. Further, 

the constellation ensures that a variety of frequencies can be reused effectively 

across different satellites to enhance the flexibility, capacity and robustness 

of the overall system. 

(3) Broadband Services. The system will be able to provide broadband service at 

fiber-like speeds, the system’s use of low-Earth orbits will allow it to target 

latencies comparable to terrestrial alternatives. SpaceX intends to market different packages of data at different price points, accommodating a variety of 

consumer demands. 

(4) Efficiency. SpaceX is designing the system from the ground up with cost-effectiveness and reliability in mind, from the design and manufacturing of the 

space and ground-based elements, to the launch and deployment of the system 

using SpaceX launch services, development of the user terminals, and enduser subscription rates. 

SpaceX soon will begin the process of testing the satellites themselves, with the 

first two prototypes launching within the next several months. Following the successful demonstration of our space and ground technology, SpaceX intends to begin 

the operational satellite launch campaign in 2019. The remaining satellites in the 

constellation will be launched in phases through 2024, when the system will reach 

full capacity with the Ka-and Ku-Band satellites. The constellation will be operational well in advance of full deployment, and we expect to begin offering services 

commercially as early as deployment of 800 satellites. 

SpaceX is highly experienced with cutting-edge debris mitigation practices and 

has deep ties with the domestic and international institutions tasked with ensuring 

the continued safety of space operations. SpaceX has designed its satellite constellation to meet or exceed all existing requirements for safety of operations in space and 

upon de-orbit of satellites, and SpaceX is deeply committed both to maintaining a 

debris-free environment in space and to disposing of orbital assets in a responsible 

and safe manner. 

V. Overcoming the Cost of Large Constellation Deployment: Launch and 

Reusable Rockets 

While rights of way and the high costs of terrestrial connectivity for rural remote 

areas historically has limited the reach of broadband, the cost of space launch has 

been the major obstacle to the deployment of large-scale broadband satellite constellations. Affordable access to space effectively limited the size of satellite conVerDate Nov 24 2008 13:09 Mar 27, 2019 Jkt 000000 PO 00000 Frm 00016 Fmt 6633 Sfmt 6621 S:\GPO\DOCS\35753.TXT JACKIE
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stellations operating close to the earth, where shorter signal paths could lower overall end-to-end latency to levels comparable to modern mobile or fixed broadband. 

By rethinking the launch vehicles design and production, SpaceX has driven down 

launch costs. Our work to recover and reuse rockets will enable truly revolutionary 

reductions in the speed and cost of space access. Every other launch vehicle provider 

in the world discards its rocket hardware after each launch. This practice is akin 

to throwing away an airplane after every leg of a trip. However, SpaceX has invested considerable internal resources to develop and implement reusability into the 

Falcon 9. Most of a launch vehicle’s cost is concentrated in its first stage. SpaceX 

has incorporated advanced technologies that uniquely enable the Falcon 9 first stage 

to return to either a ground-based landing platform or an off-shore autonomous 

spaceport droneship after nearly every mission. 

This year, SpaceX proved out this concept with the successful launch and landing 

of three flight-proven Falcon 9 boosters, placing high-value telecommunications satellites into orbit for commercial satellite operators. Each Falcon 9 first stage will 

soon be capable of at least 10 flights with no refurbishment and many more flights 

after minimal refurbishment, resulting in significant cost reductions. 

Dramatically lower launch costs and the demonstrated capability to launch nearly 

every two weeks (or less) allows SpaceX affordably to deploy larger numbers of satellites for its own NGSO constellation at a pace not previously possible. Moreover, 

affordable access to space also allows SpaceX to refresh the constellation technology 

over time, driving down the cost of producing each satellite and making it easier 

to add capability to meet consumer demand and dynamically react to an evolving 

market. 

VI. Policy Recommendations to Facilitate the Deployment of Space-Based 

Broadband Systems Safely and Efficiently 

As the Committee considers policies that could facilitate the expansion of 

broadband access in the U.S., SpaceX offers the following recommendations: 

(1) FAA Commercial Launch License Regulations Require Modernization. As 

noted, launch is the key enabling capability for the deployment of NGSO constellations, as well as other satellite platforms that are critical to expanding 

broadband access. As such, SpaceX recommends that existing FAA launch 

statutes and regulations be modernized and streamlined to adapt to higher 

numbers of launches at a more rapid cadence. The current FAA regulations 

were promulgated in a time when commercial spaces launches were rare, and 

launch was primarily the domain of the U.S. Government. However, as the 

industry transitions from a pace of a few commercial launches per year to a 

launch per week, or more, in the near future, and new U.S. launch providers 

consider entering the market, it is essential that FAA regulations be updated 

to avoid obstructing industry growth and innovation in the U.S. domestic commercial space launch industry. 

(2) FCC Commercial Launch Spectrum Licensing Process Should be Streamlined. 

The FCC licenses the radio frequencies used by commercial launch operators 

during launch and reentry operations. Because launches originally were assumed to be by and for the government, there is no allocation for the spectrum 

used for commercial launchers. As a result, the FCC must use its experimental licensing rules through a cumbersome Special Temporary Authorizations (STA) process. This process is time-consuming for the applicant and the 

FCC, as each launch mission may have multiple STAs for launch, landing, 

and various short-range communications with the payload. Each STA is limited in validity to a maximum of six months; and is approved on a non-interference basis, with ‘‘special conditions’’ that ensure frequency coordination 

with other Federal users in the spectrum bands. In September 20, 2013, the 

FCC issued a Notice of Proposed Rulemaking (NPRM) addressing spectrum 

for non-federal space launch, in which it noted that the STA process is suboptimal as commercial space launches and other commercial operations in 

orbit grow in volume and frequency. 

The FCC’s NPRM would remedy this problem by establishing co-primary, interference-protected allocation status for commercial space launch companies 

and would streamline the authorization process through standard, clearly-defined application and coordination processes. The growth of the U.S. commercial space launch industry necessitates the development of a streamlined, predictable spectrum licensing process to ensure the continued growth of the industry and the effective, efficient, and prudent use of radio frequencies. 

This NPRM, now pending for more than four years, proposes a specific allocation for non-federal space launch that would allocate specific frequencies comVerDate Nov 24 2008 13:09 Mar 27, 2019 Jkt 000000 PO 00000 Frm 00017 Fmt 6633 Sfmt 6621 S:\GPO\DOCS\35753.TXT JACKIE
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mercial space launch companies. It would streamline the authorization process 

and allow for a single, five-year license for multiple like-missions (for example, 

all missions for the same customer to the same orbital plane). The allocation 

would be secondary to the Federal users already in the band, requiring the 

same coordination processes undertaken now to de-conflict any interference 

prior to each mission. Importantly, Federal agencies have agreed to this 

change, and the agency that represents Federal users of radio frequencies, the 

Department of Commerce’s National Telecommunications & Information Administration (‘‘NTIA’’) sent a letter to the FCC in September 2016 stating that 

Federal users of the frequency bands under discussion ‘‘strongly agree’’ with 

the proposed new rules. 

SpaceX recommends that the Committee encourage the FCC to act now to 

adopt the proposed rules and then move quickly to develop implementing regulations that can allow frequency authorizations to cover multiple like 

launches. This long overdue action would save time and money, and it would 

help with long-term planning for both the FCC and industry. 

(3) Systems and Technology that Achieve Spectrum Efficiency Should be Rewarded. The new generation of broadband NGSO constellations holds incredible potential to bring affordable, fiber-like broadband services to underserved 

and unserved areas of the United States. Investment in advanced technologies 

that provide spectral efficiency and operational flexibility are necessary for 

NGSO systems to increase access to reliable, high-speed broadband 

connectivity. How they share the valuable spectrum resources will be important to their operational efficiency and their ability to deliver quality 

broadband services. Unfortunately, not all aspiring operators have chosen to 

make the investment necessary to include many of these technologies in their 

proposed systems. As a result, some systems would not only make inefficient 

use of the spectrum they seek to use, but also may prevent other NGSO systems from efficiently sharing the available spectrum. 

As such, the Committee should ensure that their rules do not unduly burden 

more flexible, adaptable systems with the responsibility of spectrum sharing 

with other less sophisticated systems. Any such outcome would impose an 

asymmetrical burden that is counter to the overall FCC goals of incentivizing 

efficient spectrum sharing. Spectrum sharing policies should ensure that all 

systems have equitable access to spectrum, avoid any warehousing of spectrum by non-operating systems, and incorporate sufficient flexibility to promote and accommodate spectrum coordination among operating systems. 

Given the advent of new space-based and ground technologies, spectrum sharing is most efficiently managed by using highly intelligent and flexible satellites, as this expands the range of potential sharing strategies available to 

the operators involved. 

(4) Spectrum Use Policy in the Ka-and V-Bands Should be Revised. When drafted, 

FCC policies governing the use of spectrum by NGSO constellations—specifically in Ka-and V-bands—did not envision the potential of very large constellations operating in LEO. As a result, NGSO constellations are unduly restricted from using important segments of spectrum as compared to groundbased fixed systems. While the agency has granted waivers for NGSO systems 

to operate in parts of this spectrum on an unprotected, non-interference basis, 

this approach is not sustainable over the long-term, especially as these new 

NGSO systems come online. 

Clear and reasonable rules must be developed to govern how multiple companies will share spectrum among NGSO systems. These rules are essential to 

the development and deployment of potential NGSO systems. Companies have 

proposed widely varying space architectures, ranging from highly-elliptical 

orbit systems operating from 8,000–43,500 km that focus on Arctic coverage 

to small constellations at medium Earth orbit at around 10,000 km above the 

Earth to several larger constellations operating in LEO at 1,000–3,000 km 

from the Earth. 

The FCC recently issued a Report and Order to update rules for NGSO satellite systems, including deployment milestones, geographic coverage, and allocations of radio-frequency bands. The new rules also discussed how multiple 

NGSO operators should share valuable spectrum, specifying that the preferred 

method to address interference between two NGSO systems is operator-to-operator negotiations. Where operator-to-operator negotiations fail, the FCC recommended parameters to determine where operators could interoperate and 

15 

where they would be required to simply divide frequency bands (‘‘splitting 

spectrum’’). 

Every NGSO applicant agreed that spectrum splitting is the least desirable 

and most inefficient approach to sharing frequencies, because it reduces capacity and services made available to consumers. The parameters that the FCC 

identified work well when sharing spectrum for downlinking from space, because downlinks already have power limits to protect other services so all 

NGSO systems operate at similar downlink power levels. However, when applied to uplinks to spacecraft in widely varying space architectures, the rules 

actually yield far more instances of mandated spectrum splitting because no 

comparable power limits exist. The wide disparity in uplink power levels often 

yield situations that defy coordination. 

The Committee should encourage the Commission to open a further inquiry 

on how to best optimize spectrum use among non-homogeneous NGSO systems 

to elicit further technical input and regulatory consideration. This should include review of the uplink transmissions needed to traverse across higher 

NGSO orbits in a manner that does not create broad-based interference to 

other lower-situated NGSO systems. The FCC’s inquiry should also examine 

the effect of beam-size on interference mitigation, since large geographic 

beams of some higher-altitude systems will operate without flexibility, and essentially nullify the flexibility of other NGSO systems. These technical inquiries should presume that the public interest is served by multiple successful 

NGSO systems, providing services to American consumers and using valuable 

spectral resources effectively. 

(5) Satellite Ground Station Siting Rules Must be Modified. As part of its Spectrum Frontiers rulemaking, the FCC is reviewing the rules it set out for the 

siting of satellite gateways using the 28 GHz range (Ka-band) frequencies, including gateways supporting both geostationary and upcoming NGSO constellations. The current earth station siting rules are a complex mix of numerical caps of gateways per county, and geographic avoidance of population centers and arterial roadways. These rules were designed to balance the need to 

protect terrestrial operations with satellite operators’ need to deploy satellite 

gateways in locations with access to Internet points of presence and backhaul 

facilities. However, the metrics defined for gateway siting are overly complex 

and difficult to interpret, and also may actually have the unintended effect of 

deterring satellite deployment in certain rural areas. Several satellite operators have suggested new metrics that would remove the per-county limit and 

recalibrate the siting rules. 

The FCC should streamline the Ka-band satellite gateway siting rules to reflect reasonable real-world deployment scenarios for both existing and nextgeneration satellite gateway technologies and their terrestrial mobile 

broadband counterparts. The FCC should also exempt from its siting rules 

those satellite gateway earth stations that operate under the limit set to protect mobile broadband networks, including both any per-county cap and population coverage limits. 

These clarifications will maintain reasonable interference protection for evolving terrestrial mobile networks while permitting the development of ground 

infrastructure needed to support NGSO satellite systems. Given that NGSO 

constellations could help provide broadband access to millions of previously 

unserved or underserved Americans, the FCC should adopt spectrum sharing 

rules that do not unduly constrain deployment of Ka-band satellite ground station facilities to support the delivery of innovative satellite services. 

(6) Maintaining a Safe Space Environment. Any policy environment concerning 

orbital debris should minimize risk to space systems without imposing an unnecessary burden on responsible actors. Recent concern in this arena has been 

driven by the proliferation of small experimental satellites (micro-, nano-, and 

cubesats) that are not maneuverable; by recent debris collisions and end-oflife disassembly problems with aging geostationary satellites; and, to some extent, by the potential deployment of large NGSO constellations. 

To reduce conjunction risks, policies should be pursued that encourage responsible and reliable satellite design and operation from launch to disposal. Future policies should balance a satellite’s deorbit reliability with the risk of a 

premature failure when considering whether to extend the satellite’s use after 

it reaches its design lifetime. Regulations can encourage and reward manufacturing designs that allow for easier tracking (e.g., tracking reflectors) and are 

fault-tolerant and safe, particularly with respect to battery and propulsion sysVerDate Nov 24 2008 13:09 Mar 27, 2019 Jkt 000000 PO 00000 Frm 00019 Fmt 6633 Sfmt 6621 S:\GPO\DOCS\35753.TXT JACKIE
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tems. Such designs would utilize materials that diminish the risk of generating new debris from internal faults, impacts with untracked debris, or 

planned de-orbit reentries. Additionally, current international policy guidelines mandate satellites have the capability for disposal within 25 years; this 

time-frame should be shortened. Given the diverse Federal agencies employed 

with space regulation and policy matters, SpaceX welcomes the establishment 

of the National Space Council and encourages robust inter-agency dialogue to 

root agency policies in common objectives and premises, even if the diverse 

agency authorities and space missions under each agency’s oversight results 

in distinct specific regulations. 

SpaceX also supports broad sharing arrangements among space operators to 

increase the accuracy of ephemeris data and mitigate potential conjunction 

events, even while space activities expand. Expanded data sharing will augment reliance on the space surveillance network for positional information and 

reduce positional uncertainty, reducing unnecessary on-orbit maneuvers. In 

addition to increased data sharing among operators, the United States should 

consider investments in orbital object tracking radars and other systems to enhance the amount and quality of space surveillance data. 

(7) Satellite Broadband Technology Should Not Be Excluded from FCC 

Broadband Incentives. The FCC is currently in the process of reviewing rules 

for and structuring the second phase of the Connect America Fund (CAF II). 

This program, with awards determined through a reverse auction, would support up to $1.98 billion in funding over ten years to support broadband expansion to areas of need across the country. The Commission has adopted rules 

providing different bidding weights to different tiers of speed, usage, and latency applicants might select. This is a reasonable means by which to ensure 

the best service receives the most favorable score in the bidding process, 

which is inherently in the interest of the American consumer. 

However, current rules preclude all satellite systems from meaningful participation, simply because current-day geostationary satellite offerings do not 

meet the FCC’s high-speed, low-latency criteria. Even if next-generation 

NGSO satellite providers could provide equivalent or better services than the 

top tiers outlined in the rules, these systems are still precluded for participating. This creates a false presumption that all satellite technologies are now 

and forever unsuitable for consumer broadband, and therefore ineligible for 

support in areas where NGSO systems are uniquely designed to serve customers competitively and cost-effectively. Conflating NGSO systems and traditional geostationary systems would be the same as the FCC prohibiting fiber 

systems from bidding because dial-up is not fast enough: just because both 

systems are hard wired does not mean that they are equivalent. 

The original CAF rules also require a stand-alone voice telephony service, 

meaning that bidders for the fund cannot offer only internet-based Voice over 

IP (‘‘VoIP’’) services like Skype or Vonage but must bundle a land-line-type 

service. This adds inefficiency and cost, and creates another bias against nonwireline bidders. 

The FCC should remove constraints on any qualifying technology to participate, and update or eliminate the existing general preclusion for satellite bidders. By doing so, the FCC will demonstrate a clear commitment to resultsbased regulation, with a CAF II auction that supports broadband in the areas 

that need it in the most cost effective, administratively efficient way. Moreover, the Commission will achieve this goal while ensuring that every bidder— 

no matter what technology it might use—has a meaningful opportunity to participate. In addition, the Commission should remove the unnecessary requirement to provide standalone voice service rather than simply make voice-overIP capabilities. 

(8) Next Generation Satellite Systems are Broadband Infrastructure and Should 

Be Included in Any Infrastructure Legislation. The expansion of satellite 

broadband through U.S.-based constellations is, fundamentally, a national infrastructure project, even though many components of the infrastructure will 

be in space. In prior investment rounds and through funds like the Universal 

Service Fund (‘‘USF’’), satellite broadband was often an afterthought. For example, of the $6.9 billion awarded for broadband infrastructure through National Telecommunications and Information Administration’s (‘‘NTIA’’) 

Broadband Technology Opportunities Program (‘‘BTOP’’) and the U.S. Department of Agriculture’s Rural Utilities Service (‘‘RUS’’), only approximately $100 

million went to satellite systems, or less than 1.5 percent of all funds approVerDate Nov 24 2008 13:09 Mar 27, 2019 Jkt 000000 PO 00000 Frm 00020 Fmt 6633 Sfmt 6621 S:\GPO\DOCS\35753.TXT JACKIE
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16 National Telecommunications and Information Administration, U.S. Department of Commerce, Broadband Technology Opportunities Program (BTOP) Quarterly Program Status Report 

(March 2017), available at https://www.ntia.doc.gov/files/ntia/publications/ntia_btop_31st_ 

qtrly_report.pdf; and U.S. Department of Agriculture, Rural Utilities Service, Broadband Initiatives Program Final Report (December 2016), available at https://www.rd.usda.gov/files/reports/RUS_BIP_Status_FinalReportDec_2016.pdf.pdf. 

priated.16 In many ways, this was the result of limitations at the time on satellite capacity, high latency rates due to satellite distance from the Earth, and 

relatively slow data rates compared to terrestrial and mobile networks. It was 

also related to a general failure of imagination to make investment and subsidy structures applicable to satellite infrastructure and consumer hardware, 

since satellite systems have few ‘‘shovels in the ground.’’ 

However, as satellite-based broadband achieves speeds, latencies, and pricing 

equivalent to terrestrial and 5G wireless technologies, it becomes especially 

critical for Congress and Federal agencies to reconsider how these systems can 

participate in national infrastructure investment programs and other Federal 

initiatives to close the digital divide. Infrastructure associated with a satellite 

broadband system includes launch facilities, consumer terminals that are 

placed on homes or businesses, gateways that will be placed at potentially 

hundreds of Internet points of presence (‘‘PoPs’’) throughout the United States 

that are used to route traffic, large antennas to track and control the satellites 

in space, and satellite operations centers. The satellites themselves are essentially infrastructure in the sky, a network that is not dissimilar to cell towers 

or underground fiber. 

As such, SpaceX encourages the Committee to take steps to ensure that satellite-based broadband infrastructure is duly captured in any Federal infrastructure, incentive, or tax policy legislation undertaken to expand broadband 

access in the United States. Such an approach will not only ensure that Congress and regulatory agencies maintain a technology-neutral approach, but it 

will also ensure the U.S. Government and American consumers are positioned 

to benefit from the significant innovations and great promise of that satellite 

systems are poised to bring. 

Mr. Chairman, I appreciate your invitation to testify before the Committee today. 

SpaceX looks forward to being part of the solution to expand access to high-speed, 

reliable, and affordable broadband Internet connectivity in the United States and 

worldwide. 

The CHAIRMAN. Thank you, Ms. Cooper. 

Mr. Dankberg. 

STATEMENT OF MARK DANKBERG, FOUNDER 

AND CHIEF EXECUTIVE OFFICER, VIASAT, INC. 

Mr. DANKBERG. Chairman Thune, Ranking Member Nelson, and 

members of the Committee, I’m Mark Dankberg, Co-Founder and 

CEO of ViaSat. Thank you for the chance to testify on the U.S. satellite industry and the critical role it plays in closing the digital divide in connecting millions of mobile devices and in our national 

defense. 

ViaSat is an American success story. Started in my house 31 

years ago, we’ve generated billions in revenue, gone public, and created almost 5,000 high-paying jobs. 

Six years ago, we launched our first satellite to deliver truly competitive broadband services directly to rural America, to airlines, 

and even to Air Force One. Though a space newcomer, we’re redefining satellite. Our first one had 100 times the bandwidth of a typical satellite; our second doubled that; and we’re building one now 

1,000 times better than the typical satellite still in use today. The global satellite industry is valued at $260 billion a year. The 

U.S. has the largest share. Satellite service is the biggest segment 

and the economic engine for commercial space. Advances in spaceVerDate Nov 24 2008 13:09 Mar 27, 2019 Jkt 000000 PO 00000 Frm 00021 Fmt 6633 Sfmt 6601 S:\GPO\DOCS\35753.TXT JACKIE
18 

craft and rockets depend on demand for satellite services. Communication is the largest piece of services, and broadband is the fastest growing part of communications. 

Broadband satellite demand has skyrocketed as media and entertainment evolves from broadcast to Internet-enabled to on-demand 

service. If you’ve ever seen a frozen Internet videostream, you 

know the pain of slow broadband. 

Today, we deliver faster Internet to hundreds of thousands of 

American homes. We’ve grown without subsidies, competing 

against much larger companies. We see the market work. When 

our service is faster, people choose ViaSat. 

In 2012, our download speed was 12 megabits per second, above 

average back then. Our second-generation satellite reaches 100 

megabits per second, again, above average for all U.S. broadband. 

We’ve invested heavily. We built our own payload factory, employing hundreds of people. In 5 years, we’ve invented three generations of satellites, aiming to bring fiber-like speeds to Americans 

left behind by other technologies. We’re still designing even faster 

versions. 

We’re disrupting in-flight WiFi, too. Not long ago, airborne WiFi 

and the terrestrial wireless link, so slow and expensive, hardly 

anyone used it. We now bring satellite WiFi to every JetBlue flight 

free to every passenger and with enough bandwidth to stream 

video. It’s so popular, there is often more connected devices than 

passengers. We have expanded to large portions of United and 

American Airlines, too. 

We’re exporting to international airlines. The global airline industry sees satellite WiFi as the future, with over 3 billion global 

passengers a year, and over 800 million in the U.S. We believe 

competition works. 

ViaSat embraces the entrepreneurial spirit and competes with 

the largest companies in the world. Now there are dozens of 

startups and satellites in space, and we believe our success helps 

to inspire others. 

But there’s a threat to American satellite growth. Broadband 

needs spectrum. Our technology uses spectrum extremely efficiently. And we helped the FCC open the 28 gigahertz band for 5G 

while still enabling growth in satellite broadband by sharing the 

same band. 

Yet, sadly, the FCC’s most recent NPRM would take spectrum, 

long allocated for satellite growth, and designate it almost exclusively to terrestrial wireless. This is the 47 to 52 gigahertz band. 

We’ve been investing heavily in the technology that allows us to 

use the spectrum in the next 5 years. Such a policy decision would 

pick winners and losers, and stifle competition. The problem is not 

in accommodating 5G, it’s in taking spectrum away from competitive satellite services and creating exclusivity by regulation. 

It need not be a zero-sum game. There is no technical argument 

against spectrum sharing. ViaSat has put extensive technical studies on the record in spectrum frontiers from independent experts 

showing satellite terrestrial spectrum sharing can work. There is 

no policy reason to limit competition that can bring the best 

broadband services to American consumers, businesses, and government users. 

19 

In summary, demand for satellite broadband is at an all-time 

high. We’re providing a service that is competitive with urban offerings, and we’re uniquely suited to serving the rural Americans 

other technologies have left behind. There is much more innovation 

to come. Technology markets are dynamic and evolve in unexpected 

ways. 

ViaSat is committed to serving all of America. We just need the 

spectrum tools to do so. 

Thank you again for the opportunity to appear before you today 

on these important issues. And I’ll be happy to answer questions 

that you may have. 

[The prepared statement of Mr. Dankberg follows:] 

PREPARED STATEMENT OF MARK DANKBERG, FOUNDER

AND CHIEF EXECUTIVE OFFICER, VIASAT, INC. 

Chairman Thune, Ranking Member Nelson, and Members of the Committee, I’m 

Mark Dankberg, co-Founder, Chairman and CEO, of ViaSat. Thank you for lhe 

chance to testify on the U.S. satellite industry—and the critical role it plays in closing the digital divide, in connecting millions of mobile devices, and in our national 

defense. 

I’ve lived the American entrepreneurial dream. Since ViaSat started in my house 

31 years ago, we’ve generated billions in revenue, gone public, and created almost 

5,000 high-paying jobs. 

Just six years ago, we started redefining satellite broadband when it was apparent that existing technology was not up to the task. We designed our first satellite 

to extend urban-quality broadband services to rural America, airlines, and even Air 

Force One. That satellite delivered 100 times the capacity of a typical, satellite and 

today provides 25 Mbps speeds to large parts of the Nation. Our second generation 

design, launched this year, doubles that capacity, covers the entire nation, and supports speeds of up to 100 Mbps. We’re now building a third generation design with 

nationwide-coverage, 1,000 times the capacity of the typical satellite in use today, 

and support for fiber-like speeds. And we’re designing even faster versions. 

More capacity means better service. It allows us to keep up with the growing demand for our services, provide even more customers at urban quality offerings, and 

support the video-streaming services that Cisco estimates will represent 82 percent 

of Internet usage within a few years. 

We see the market work. When our service is faster than the competition, people 

choose ViaSat. This is true not just in the consumer broadband sector, but also in 

the in-flight WiFi sector. 

Before us, in-flight WiFi was slow and expensive, and hardly anyone used it. We 

have developed satellite-delivered WiFi !hat serves every JetBlue flight—free to 

every passenger and with enough bandwidth to stream video. It’s so popular, there 

are often more connected devices than passengers. In fact, we connect over two million personal electronic devices per month on airplanes. And we have expanded to 

the United and American fleets. 

We’ve invested heavily to serve the Americans others have left behind. We built 

our own factory to allow us to do what no one else was doing. And we’re actively 

exporting this American satellite technology around the world. 

ViaSat embraces the entrepreneurial spirit and competes with the largest companies in the world. There are now dozens of start-ups in satellite and space. We believe our success played a role in inspiring others. And ii is clear that advances in 

spacecraft and rockets depend on demand from commercial satellite operators like 

us. 

But there’s a threat to the ability to continue this American innovation and its 

ability to serve rural America. Broadband satellites need spectrum to achieve these 

goals. 

Our technology uses spectrum extremely efficiently. Last year, we helped the FCC 

open the 28 GHz band for 5G mobile wireless while still enabling growth in satellite 

broadband, by sharing that same spectrum. 

Yet, sadly, the FCC’s most recent NPRM would take spectrum long-allocated for 

satellite growth and make it available almost exclusively for terrestrial wireless operations. This is the 47–52 GHz spectrum that we have been planning to use on 

our satellites in the next five years. Such a policy decision would pick winners and 

losers—and stifle competition. The problem is not in accommodating 5G—it’s in takVerDate Nov 24 2008 13:09 Mar 27, 2019 Jkt 000000 PO 00000 Frm 00023 Fmt 6633 Sfmt 6621 S:\GPO\DOCS\35753.TXT JACKIE
20 

ing spectrum away from competitive satellite services und creating exclusivity by 

regulation. 

There’s no technical argument against spectrum sharing. Since there’s no technical reason, there’s no policy reason to prevent limit competition, stifle the ability 

to bring the best broadband services to America consumers and government users, 

and foreclose the ability to provide services we can’t even imagine today. 

In sum, the demand for satellite broadband is at an all-time high, we are providing a service that is comparable to urban offering, and we’re uniquely-suited to 

serving the rural Americans that our competitors have fell behind. The key to our 

ability to continue to innovate and drive developments in American technology is 

access to adequate spectrum. 

ViaSat is committed to serving all of American. We just need the spectrum tools 

to do so. 

Thank you for the opportunity to appear before you today to discuss these important issues. I would be pleased to answer any questions you might have. 

21 

ATTACHMENTS

Report on Satellite Earth Station Shielding Testing 

Filed with FCC April 20, 2017, GN Docket No. 14–177. 


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22 


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measurement locations. Second, to determine if the antenna transmitting at the nominal 

power density of a third generation AJF woufd meet the expected power flux density (pfd) value 

at the distance flied In theViaSatApril21 Ex Parte. 

Transmitting Antenna CharacteriStiC$ 

While minor performance differences due to different feed configurations can be expected, the 

1.8 m antenna in question is representative of the type of 1.8 m antenna to be used for future 

AIFs for the ViaSat third generation HCS satellites. The antenna is roof mounted on a threestory building with parapet wall of varyll'\g height around the roof top. The parapet wallis part 

of the architectural design of the building and provides visual screening of roof top equipment 

sudl as HVAC units and other antennas. The height or the parapet wall varies between one and 

a half and three feet. In addition to the parapet wall, the roof of the building also includes a 

recessed area approximately two and half feet deep to further aid in screening roof-top 

equipment from view. 

The 1.8 m antenna is mounted In the roof top recessed area and aligned to poJnt at the 

Wild81ue· 1 satellite at 111.1° W.L The nominal pointing angles for this spacecraft are 168.8° 

azimuth and 50.1° elevation. 

Because no measureable signal had been detected at ground level during prior testing. the 

testing with Comsearch was configured to use a CW carrier rather than a modulated carrier to 

provide 3 better C/N and increase the likelihood of signal detection at the various measurement 

locatfons. To operate the antenna~ the testing used a standard ViaSat integrated assembly 

which incorporates a combined modem and radio frequency transceiver all in one module. 

The power tnto the antenna feed was configured to be 0 dOW (1 W) and verified at the antenna 

feed port to be .0.4 dBW using calibrated test equipment prior to the start of testing. 

Comsearch verified that the bursting ON signal being transmitted at the frequency of 

28212.5 MHZ was readily observable a1 the roof·top location, inside of the parapet wall, with 

the spectrum anatyzer configured to maximum hold. 

f ollowing confirmation of source signal calibration, Comsearch PfOCeeded to make 

measurements at various focations in the area around the building at both ground level (2 m 

AGL) and at the FCC referenc-e Spectrum Frontiers Order UMFU operational antenna height of 

10m AGL. Photos of the test locations and screen shots of the spec-trum ana y~cr plots can be 

found in Section 3 of the Comsearch repon, and a summary of the resultant signal level 

measurements are provided in Tables 4.1 and 4.2 in Sectlon 4 of the Comsearch report. 

Ana1'($iS 

There are two parts to the analysis. The first part examines whether a signal was present at a 

location when Comsearch made their measurement, and If so how the signal compared to the 
23 


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predicted value assumins rree space os~ alone and whether there WC!re additional losses in 

the path. The second part uses the measured signal values and other Information about the 

Via5at AIF to calculate the power flux density associated witll each measurement. Both of 

these analyses arc de-scribed below. 

Sigflol Prt?sence Measurement and Additional LoS5es Anolysh 

Comsearch performed measurements with calibrated test equipment using the industry 

standard signal subst,itution method, as recommended by the National Spectrum Management 

Association {NSMA}. s The signal value rcsulls recorded In Table.s 4.1 and 4.2 of the Comseareh 

report and represent the measured level of the CW carrier transmitted from the 1.8 m antenna 

system be ins tested, as reduced by path loss and additional losses between the antenna and 

measurement kx:ation. It should be noted that the recorded values suffixed with NF indicate 

that no signal was observed above the measu((~ment S'(Stem's noise floor (I.e., the recorded 

value was that of the noise floor in that instance). Because a spectrum anatvzer functions flke 

any other receiver, its nots.e floor is affected in the same way by signats {or interference) being 

recefved. The Increase in the displayed response above the noise floor In dB Is calculated as: 

( 10 log !!!!) 10 1 + 1010 , where I and N are the actual interference and noise levels (11 

For cx;:,mple,lf the received signal is equal to the noise floor, the two add in amplitude and the 

displayed response is twice that of the noise alone and a 3 dB rise above the noise floor Is 

observw. Aslgnal ·12.2 dB lower than the noise floor results in a 0.25 dB Increase In the 

displayed value. Given that no visible respons-e was seen on ttle analyzer, the- actual signal 

value then was likely more than 10 dB below the noise floor'. 

To determine the additional loss, if any, over and above free spaGC path loss in the direction of 

the measureme-nt location, the EIRP in tha ditection of the measurement location must fii'St be 

determined. 

To do this, antenna gain in the direction of the measurement location is added to the 

ttansmitter powN being applied the antenna feed. Tables 4.1 and 4.2 of the Comsearth repOrt 

contain the azimuths to and from the transmitting antenna, as well as the distance In meters. 

The Com search tabl~ do not, however, reference the beating along which the antenna is 

transmitting. nor is the elevation angle of the transmitting antenna included. 

s The National Spectrum Management Association (see URL: http://nsma.or&D 

Recommet~datlon WG 4.88.013 Rcv.l 6 Spectrum Analyzer Noise Measurements, HP Application Note 150-4, 1974; and Spectrum 

Analyzet Measurements and Noise, Agilent Application Note 1303. 
24 


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The transmit .antenna's bearing and the elevation angle lnfotmatlon are needed In order to 

determine the off..axls angle in azimuth and in elevation in order to determine the estimated 

off~axis gain discrimination in the direction of the signal measurement sire. This Information is 

provided in the Tr.lnsmlttlng Antenna Characteristics section above. The operating azimuth 

angle of the 1.8 m antennJ is 168.82~ (as referenced to True North at 0°) and the elevation 

angle i.s 50.1~. 

With this information and the antenna gain panerns, the EIRP density in the direction of the 

measurement site c-.an be calculated. For example, for measurement Site 1. the azimuth an.glc 

from the uansmittlng antenna toward the measurement site is given as 170.29° in Table 4.1 of 

the Comsearch report. Subtracting the transmitting antenna's bearing toward Wlld81uc·1 of 

168.82° from 170.29° yields an off-axis angle of 1.47° . By examining the manufacturer's 

antenna gain patterns, attac-hed as Annex 2/ It can be seen that the off·axis gain discrimination 

In azimuth Is 35 dB and the gain discrimination in elevation is 70 dB, so the larger of the two 

values is used. In reviewing the otr-axis angles for each .s-Ite, it can be seen that for all 

measurement locations, the larger 70 dO elevation off-axis eain discrimination value applies. 

The nominal gain at 28.212.5 GHz is 52.59dBi and the input power to the antenna Is -().4 dBW, 

so the EIRP toward the horizon is ·0.4 dBW + (52.59 dBi- 70 dB) o ·17.81 dBW. 

Using the free spac:e path loss (FSL) formula (2), the expected FSL for the 66.14 m distance is 

calculated In d6as97.86 dB. 

101on(l7n (2) 

The expected measurement value is then the EIRP- FSL • -11S.67 dBW. The aetual measured 

value recorded for Site 1 in Table4.1 was ·137.51 dBW. The additional loss is then ·115.67 dBW 

minus · 137.51 dBW • 21.84 dBW. 

The process was repeated for each of the measurement sites and measurement heights (2m 

and 10m) and the r~vtts are recorded In Table 1. 

7 1\nnex 2, General Oynarnks Antenna Test Report. 
25 


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Conoo<lo<l"'""""' 

Measurement Mensurement Free Space Rec01ded Signal Expected Additional losses 

location Hc1ght (m} Loss(dB} (d8W} Sigr~>l (dOW) (d6} 

Site 1 10 97.86 -137.51 -115.67 21.84 

Sitel 2 97.86 ·158.19 NF ·115.67 I> •2.s2 Sitt2 10 98.30 -149.10 ·116.11 32.99 

Site2 98.30 -155.56 NF •116.U I> a9.45 

Sitt3 10 103.43 ·141.30 ·123.24 18.06 

Stte3 103A3 -159.65 NF ·123.24 1> 36.41 

Site4 10 10'7A6 ·133.25 ·125.27 7.98 

Sit•• 2 107.46 · 160.00 NF ·125.27 !> 34.73 

SiteS 10 111A6 ·140.68 ·129.27 11.41 

Sit•5 11 1.46 ·147.78 ·129.27 18.51 

Slte6 10 112.33 ·144.95 ·130.14 14.81 

Site6 112.33 -154.82 ·130.14 24.68 

Site7 10 110.59 ·155.96 NF ·ll8.40 1> 27.56 

She? 2 110.59 ·158.19 NF ·128.40 !> 29.79 

SiteS 10 109.03 ·158.63 NF ·126.84 '> 31.79 

SHeS 2 109.03 -158.63 NF -126.84 1> 31.79 

Site9 10 111.04 · 1.58.10 NF ·128.85 I> 29.25 

Sites 2 111.04 ·159.44 NF · 128.85 > 30.59 

SitelO 10 112,47 · 158.60 NF · 130.28 > 28.32 

Site 10 2 112.47 ·158.?7 NF -130.28 I> 2s.49 

Sitelt 10 98.87 · 157.48 NF ·116.68 I> 40.80 

Sitell 2 98.87 ·158.78 NF · 116.68 > 42.10 

Tobie ! Recotded vs bpttttrd Signals and Alldillonol to»f's for M('(l$1/ttme.nt t""tions 

Examining the results in Table 1 shows that in many cases for the 10m reference height and for 

the majority of the 2m height measurement locarions, no signal was obscf\1~ nbove the test 

equipment noise ftoor. The largest observed signal was at the Site 4 1a<:ation. The 

measuremel"'t locatlon also had the lowest additional losses above the expected free space loss 

of 8 d8. This result was anticipated because the terrain at that signal test location is 

approximately 20 feet above the terrain at the base of the building on which the transmitting 

antenna Is located. Also, from the Comsearch photos it can be seen that the parapet wall on 

that area of the building where the transmitting antenna is located was at the lowest height 

and the me:asuring antenna had a line of sight view to the transmitting antenna. Raising the 

parapet wall in the direction of the higher terrain would provfde additional blockage and 

lnucasc the: losses above the FSl. 

Power Flux Density Measurement 

The second part of the analysis is to determine the power nulC. density at each of the 

measurement locations. To use the Comsearch results meaningfully, the recorded signal level 
26 


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values must first be scaled to a reference bandwidth and converted to a Rux demity. That is, 

converted from dBW to d8W/fm2 • MHz}. 

While the transmitted power of the unmodulated CW carrier from the 1.8 m antenna is known, 

to convert the power to a power density that represents the third generation AJF, the 

modulated bandwidth a.ssociated with tha·t power level in normal operation must be known or 

calculated for usc In tllc density corwerslon. 

In the VlaSat Apri116 EK Porte, the antenna Input de-nsity for the third generation AIF was 

projected to be -19.0 dSW/MHz. However,since that ex porce was filed, ViaSat has further 

reduced the expected nominal antenna Input power density for this dass AIF 

to ·24.3 dBW/MHz. 

The C<juivalcnt bandwidth over which the 0.4 d8W input power to the 1.8 m antenna would be 

spread in normal operation of a third generation AJF is then 10'(.0.4/10)/10'(·24.3/10) = 

24S.SMHZ. 

To calculate the power der\Slty In dBW/MHz, the bandwidth adjustment in dB Is calculated as 

10 log (245.5 MHz/1 MHz) = 23.9 d8(MHz). This result is subtracted from the measured value 

to calculate the power density. For Site 1, this is ·137.51 dBW- 23.9 dB(MHz) 

= ·161.41 dBW/MHz. 

To complete the convet'$ion from power density to power flux density {pfd); the meter squared 

area gain is added to the power density. 

Meter squared area gain= lOiog~ = 50.46 dB/m2 

The measured pfd is then ·161.41 dBW/MHz + S0.46d8/m' = ·111 dBW/(m' • MHz), 

or ·81 dBm/(m' • MHz). 

(3) 

The conversion process was repeated for eac.h of the measurement sites and measurement 

heights (2m and 10m) and the results were recorded In Table 2. 
27 


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Cortodec5 412112011 

Power Power'Fiu)t 

Measurement O~Mity ocnsity 

Location (dBW/MHI) (dBW/(m•2'MI"tl) 

Sitel ·161.44 -110.98 

Sitet ·182.12 < -131.66 

stte2 ·149.10 -173.03 -122.57 

sne2 ·155.56 NF ·179.49 ·< -129,03 

SOte3 10 -14L30 -165.23 ·114,77 

Site3 2 ·159.65 NF ·183.58 ' < ·133.12 

Site4 10 -133.25 ·157.1& ·106.72 

Site4 · 160.00 NF ·183.93 < -133.47 

SiteS 10 ·140,68 ·164.61 ·U4.15 

SiteS 2 ·147.78 ·111.71 ·121.25 

Site6 10 ·144.95 ·168.88 -118.42 

Sitc6 ·154.82 -178.75 -128.29 

SOtc7 10 -155.96 NF I -179.89 < -129.43 

Site7 -158.19 NF ·182.12 < ·131.66 

Site8 10 -158.63 NF ·182.56 < -132.10 

SiteS ·158.63 NF ·182.56 < ·13UO 

Site9 10 ·151UO HF ·182.Q3 < ·131.57 

Site9 -159.44 NF ·183.37 < -132.91 

Site 10 10 ·158.60 NF ·182.53 < -132.07 

SOte 10 2 -158.77 NF -182.70 < -132.24 

Site 11 10 ·157.48 NF -181.41 < ·130.95 

Site 11 2 ·158.78 NF -182.71 < -132.25 

Examining the resuhs in Table 2 it can be seen that all but one measured value was below the 

Spectrum Frontiers Order sharing criteria limit of -77.6 d8rn/(mz • MHl:}. The measured value 

for Site 4 which had the highest terrain and ow~t additional losses, was the only value which 

exceeded the FCC limit. The exceedanre of the limit by 0.9 dB, would easily be mitigated by a 

modest increase ;n the parapet wall on that side of the building where terrain is higher. 

Conclusion 

While the transmitting antenna tested here no--mally ope. at~ In the oonventionaJ Ka band, and 

ac~rdingty was not sited with SG/UMFU sharing constraints in mind, this type of roof top 

mounting scenario is quite common for modest sized earth stations in urban or subutban 

commercial settings. Even with no special care taken to mitigate signal levels toward the 

horizon, the measured levels fOJ all but one location wefe below the FCC's sharing criteria, and 

in many cases significantly so. 
28 


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With some care used in new installations, it would be fairly ~asy to shield the antenna from 

nearby SG/UMFU operations and thereby allow siting of earth stations close to fiber even in 

urban env!ronmeflt:S where SG/UMFU will be or has deployed. 
29 


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DECLARATION 

I hereby docl3rc that I tlm the tcchnica.Hy qwtlified person responsible for 

preparation of tho en&ineeting iofonnatioo contained in this report. that 1 am fami.lllll' with Par1 

2S of the Commi:ssioo•s roles. that 1 havo cilbt;r prepared or reviewed th.c engjneering 

information submitted with this report, and th:l1 it is comptc,.-tc l'lnd accurate to the best of my 

knowledge, information and belief. 

llpril 12, 2017 
30 

ANNEX 1—COMSEARCH REPORT


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~ comseorch. 

RADIO FREQUENCY SIGNAL 

MEASUREMENT REPORT 

Prepared For 

ViaSat 

Carlsbad, CA 

Transmit Station 

28 GHz 

February 2017 

19700 JaM/Itt FMm Boulevard. · A.shbum, Vlrg1nlll 20f41, USA • 703. 725.550() · Fax 103. 126.$$91 
31 


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·rABLEOFCONTENTS 

SECTiON ( lut•·oduction and Uackground 

1.1 Introduction 

1.2 nnckg:rauod 

1.3 Assumptions & Constrnints 

SECTION 2 Te.<ll'rocedure 

2.1 Calibration 

2.2 Met hodolo:zy 

SECI'JON 3 l)gta Presentation 

SF:CTION 4 Suummry or Results 

SJ!:<: nON S Conclusions and Rec.ommeodations 

5.1 Contlu.sion.s 
32 


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SECTION I 

INTRODUCTION AND BACKGROUND 

1.1 rntroduc.1iun 

On-site Radio Frequency (RF) transmission measurement~ wete perfonued on behaJf of ViaSat. 

Inc. on f ebnaary 14,2017 at their existing site in Carlsbad, CA. 1'he purposcoftho m(..'U\Irtmcnts 

was codetermine relative RF levels in tJ1c 27.5 28 35 G.Hz band with rcspecl to expected free space 

loss and to evaiU!lte the effectiveness of using a typical rooftop earth station installation co screen 

t:rtUlSJ'nissions from nearby terrestrial rc«i.vers.. The purpose of this report is to document lhc 

results of these measurcmcnlS: 

• 1.8 Me!er TX Antenna 

• Satellite Arc: Il l. I Degr= West Ulngitude 

• Frequency COn$idcted: 28,2 12.5 MHz 

• 1'mnsmit Power: I Watt / 30 dOm 

• TypeofReeeption: CW 

• Mcasurod Rx Antenna Center Line: I 0 meters Above Ground Level 

1.2 Uaekgroum1 

ViaSOl, Inc requested that Comscarch perform receive level testing using a calibrated system to 

measure receive signal levels from a CW CarTier being transmitted from a rooftop mounted 1.8-

mctcr anterma io the areas surrounding the antenna. The antenna is located on the roof of a 3 story 

building, in the center portion of the roof. in a depressed ar¢a. The coordinate." of the test transmit 

antenna nrc: )3° 0 1' 38.31"N and 117" IS' 55.13"W. Tile roof has a short parapet 1vall (varying 

between approximately 1.5 feet and 3 feet) at the edge but no other substantial items which would 

ptovide blockage. The ontcuna is located in a depression in the roof which is approxima(cly 2.S 

feel deep. 

An lU1.010dul3ted CW carrier was used because previous testing u( ground level using a modulated 

carrier httd resulted in no detectable signals. Ry using a CW c.atrier, the power density in the 

mea.tourement bandwidlh was increa.~ed considerably. Additionally, testing at both ground level (2 

m) and I 0 m were requested for the new tests in order to improve the likelihood of detecting a 

signal above the noise floor of the measuring equipment. 

TI1c g:mund test locations were determined by drawing multiple ares at 50 meter distances from 

the building and where lhose circles intersected with dte main beam .. 45 and 90 degree orr main 
33 


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beam locations. Tests wcro oonducted as clo5c as possible 10 !hose crossing$ where 

possible. Bcca""' of lhc lacl: or signals abo>c the noi>c: floor during pta'ious tests and the 

dtiTK:ulty of ClOSSio& lhc busy roadway 10 the West of the antenna with the boom lift. lcstina on 

lhal side or lhc stm:1 was plamed only if IC>lm&thcre was deemed wamnted. 

lllemeuun:mentsics""' idcntifoedon 1 poflion ofa ~ mapsbo.-n in F'll\Ure 1.2·1. An 

l<:raal photo oflhcsile locations aresbown m fi&ure I 2·2 

1lte analysis to this report is based upon the follow in~ a'I.Sumptl0f1S and constraints. 

• Lt was verified that during lhe measurement period the trnnsmh antcrmtl was nc:livc find 

operating at the specified tmnsmit pOwer 1 t dU. 

• 1bc signal identification and fff:qutncie!l or the ltM cnrricr wete specified by ViaSat. 

• Tho actual ground cleval:ion ofthe$ite •s based on the data from the topographic map. 
34 


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35 


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SECTJON2 

TEST PROCEDURE 

2.1 Caljbr:ttion 

Figures 2.1-1 is d1e block diagram of the rest set for all bands to be tested. All test equipment used 

was allowed a proper warm .. up period prior 10 calibration. l ite test set W{IS cnlibnued by the signal 

substirution method, as recommended by NSMA, utilizing R synth~ zecl ~ignal generator. ·n te 

reference signal from the signal genen.tor was adju.trted for the center frequency of each band to 

be tested and measured with a thenna.J power meter for calibrated reference test level (·GO d.Bm). 

This calibratod reference sign .. 11 from lhe signal generator was then injected into the end of the 

coaxial cable of the test set at the point, which nonnally connects to the test antenna. A spectrum 

analyzer then measured the rcf<.:rcnce test signnl level after passing through the test set. Upon 

completion of the calibration process, a known reference level was obtained for the mca.~urcments 

thut corre.'>pOnd to a given set of spectrum Mal)?'.er display readings. 

The following fomlUia is used to transfonn the measured signal level us d on 1he Speclrum 

Malyzer display (dBm) to an isotropic reference signal level (dBW1) llS seen nLthe point of test 

dBWo - U - EG -30 

Where: dll\Vo Isotropic level in dll\V 

Ll - Level (dBm) of io~<x: ed signal 

RG External Gain ·Test antenna gain + LNA Gain 

at 28 Gllz: dllWo- -60 dllm- 45.9 dB 

--105.9 dllmo 

In this instanec. the spectrum nnaiY'.er displayed measured signal level of - 60 d])m equates to an 

isotropic signttl lcvel of -105.9 d.Bm1. 

Figure 2.1~2 displays the spcctn1m photograph of the described ealibnttion procodure employed 

during these measurements. 
36 


1025DANK21.eps

--
37 


1025DANK22.eps

·-- ··· :::-

·-.... 

r" 

1- .. r---:--

po.- .,.-t-----i-+--1--t--+--1--l--1 

-..... 

~ -- 1- r- T-~~~T-~~~~ 

- i='r' "' +--1--1---JII--l---t- +-+--1 C.=--0.. .......... biT-,,. 

:!. ... ~ I IJt. ~ ~:l=:t~t::J:::t=t~t: ~ :t~~~-1 _..._ C... 

' <* 01-, lttttJDtO.. 

,., II- I - .. n 

A ·52. 18 dBm, 28212.5 MHz signal indicotion on !he speetrum phe)logml>h rcpresen1s a 

~60 dUm signal being injected nt the point where the test cable COI\nects to the output of the test 

antenna. 

Oisp!ay<:d reference level is equal: 

-60 dUm injected signal 

-45.9 dO external gain 

-105.9dBm,; therefore. a displayed 

signal level of -70 dBm equals an 

isotropic level of -1 16 dllma 

Adjusted measurement values (d.Bml) .shown in red 

f ig11rc 2.1·2 Calibmtion Speetrum PhelO 28 Gllz 
38 


1025DANK23.eps

2.2 Methodology 

The test equipment was set up and calibrnted to measure the RF e-nvironment. Measurements were 

conducced al in such a wny thut w(luld show if the signal from llle transmiucr Wi.\S visible above 

the teS-t equiptnCIH's noise floor ror the 27.5 28 35 G!lz band. After l.he equipment calibradon was 

eomplercd, the test antenna was mounted on a mmorizcd boom lift and elevated to a height of 10 

meters AGL. 'J'be tests were conducted by activating the peak hold Hmction of ll1c spccU\lm 

analyzer. 'Ill is enabled the analyt..cr to maintain and djsplay the maximum si_gnallevd received for 

the frequency under consideration. The tesl :;sntenna wn.~ pe.1.ked while pointed at the t.r'ansmit 

notenn.n to o.uempt to receive ruly signal from the tmnsmit antenna .• , 

Table 3. . item 8. The area OJ1 the roof where the- TX antenna is located is dcprcssod by 

approxin>alely 2.5 ft deep. 

In tables 4.1 &. 4.1. Nf =Noise rloor of test measurement sys.tem. (So readers won•t confuse this 

with SO or LMDS equipment NF). 
39 


1025DANK25.eps

SJ<:CI'ION3 

DATA PRF.SENTATION 

The following section contains the tables Md spcctn1m photos pertaining to the site location 

measured. 

3.1 Carl<bad.CA 

Table 3.1·1 presents a sire dara sheet including all pertinent site infonnation. 

Figures 3.1·J owl3. 1·2 arc the photographs depicting the existing Cilrth station site and 

test locations. 

Figures 3.1-3 (A) through 3.1 ·3 (V) are the Rl' spectrum photographs depicting the re<eive 

sig11al measured at d1e test sites. 
40 


1025DANK26.eps

TABL.: 3.H 

MEASlJREMloN'r Sl.TF. DATA ~m· 

I. SYSTllMNAME: 

2. CITY AND STA Tll: 

3. Sl'fB IDBNTIFICATION: 

4. COOROINA'fBS (I'X Si1e): 

(NAD 1983) 

5. <JROVNDELilVA'I'ION: 

6. MflASUREMENT DATE: 

7. GllOSTATIONAR Y ARC RANGE: 

SATELLITll POSITIONS: 

AZIMUTH: 

ffi,EVATION: 

ViaSat, Inc 

Carlsbad, CA 

Cnrlsbad 

LATITlJDl!: 33' OT 38 .. 31" N 

WNGITIJDB: 117"15'55.13"W 

310 feet AMSL 

fcbn•ary 14,2017 

III.I'W 

168.8' 

50.9' 

8. GEOSTATIONARY ARC VISLBILifY: ThcTX si1c is on a 3 story building wiO>a shM 

parapet wall. 11le TX antenna was also in nn area oC thc roofthal is depressed approximately 

3 feet. 
41 


1025DANK27.eps

View oflttUl.Sinitantcnna Jooking north 

View of tmn~mil ante111\a looking souLh 

Figure 3.1-1 (conL) l'.arth Slll.tioo Site Pbolographs 
42 


1025DANK28.eps

View of bllnsmit an lenni lool;i"g south 

View oftran.o;mit nntcnnalookins west 

Figun: 3.1-1 (cont.) llanh Sl•tion Site l'hO<oj\faphs 
43 


1025DANK29.eps

, I - --- - -- • 

View from rooftop looking cast 

View from roonop looking southeast 

Figurc3. 1-l(cont.) l!nrth Station Site Pholograplls 
44 


1025DANK30.eps

View from rooftop looking south 

Vtcw from roo flop looking southwest 

Figure3.1-l (conr.) l;arth Sratior• Site Photographs 
45 


1025DANK31.eps

View toward ·rx antenna on rooftop from Site I at 10m AOL 

View •oward TX antenna on rooftop from Site I at tOm AGI. (zoom) 

Figurc3.l-2T.,;t Locations 
46 


1025DANK32.eps

View toward TX ante""" on rooftop from Sote 2 at 10m AGL 

View toward 'f'X antenna on roofloJ> from Si1e 2 at I Om AOI. (1cxnn) 

Figurc3.1-2 (oont.)'lost Locotions 
47 


1025DANK33.eps

View toward TX antenna on roorlop rrom Site 3 ar 101n AGL 

View toward TX Mtenna on rooftop from Site 3 at JOm AGL (7.(')()m) 

figur<: 3.1-2 (<:<>nt.) Test l..ocations 
48 


1025DANK34.eps

View toward TX antenna on ll)OR:op from Site 4 at 10m AGL 

View loward TX anl'enno on rooftop from Site 4 at 10m AGL (7AOIU) 

Figure 3.1 -2 (cont.) Test Locations 
49 


1025DANK35.eps

View towardTX antenna on rooftop from Site 5 at lOrn AGL 

View toward TX antenna on tooftop from Site 5 at 10m AGL (?.oonl) 

Figure 3.1·2 (cont.) Test Locations 
50 


1025DANK36.eps

View toward ·rx antenna on rooftop from Sire 6 at I Om AGL 

View rowa.rd TX antenna on rooftop from Sire 6at 10m AGL (7.oom} 

Figure 3.1-2 (conl) Test Locations 
51 


1025DANK37.eps

View coward 'fX anlcnna on rooftop from Site 7 at l(hn AGt 

View loward TX antenna on rooftop from Site ?et 10m AGL (1..00n1) 

Figure 3.1·2 (cont.) TcstiACations 
52 


1025DANK38.eps

View 1oward TX antenna on rooftop from Site 8 a( JO'" AOL 

View toward TX antenna on rooftop from Site 8 •t 10m AGI.. (zoom) 

Figure 3. 1-2 (cont.) Test Locations 
53 


1025DANK39.eps

View towurd TX antenna on roofiop from Site 9 at 10m AOL 

View toward TX antenna on rooftop from Site 9 at 10m AOL (zoom) 

Figure 3.1 -2 (cont.) Test Locations 
54 


1025DANK40.eps

View towardTX an1enn:t on rooftop from Site 10 at 10m AGL 

View aoward TX antenna on rooftop fro1n Site I Oat 10m AGL (>t..oom) 

Figure 3.1 ·2 (cont) Test Locations 
55 


1025DANK41.eps

View toward TX anteru1a on rooftop from Site II at 2m AGL 

View toward TX anlenna on rooftop from Site 11 at 10m AGr .. (zoom) 

Figure 3.l-2 (coot.) T .. l l.ocalions 
56 


1025DANK42.eps

~412Gt20t7 

!hV'Itsu ....,...liN-410,. 

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I Ofll Cln'tt:U.Ut .tlot!lkf ·t1.tt• 

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._ 

--...... 

-· 

F'igurt 3.1-3 (A) Spectrum l>hotoo28 OHz:- 100 Jc.H~ Res llW Site I at 10m AGI.. 

lhwftSU ..uwttl71itltle 

.... .... 

·... --

--

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= 

~ --,_ 

......... 

. .. 

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Iii ca ~ I .,., ___ 

... 

-

--· 

--·---...... ......... 

Figuro3.1 -3 (II) Spectrum Pl•otos23 Gllz ·lOll kllzRes IJW Site I 312m AGI. 

Adjuslod mc:as-urement values (dHtlll) shown in rod 
57 


1025DANK43.eps

COfl'eoCtltdo112112117 

l/lrvltsu ~l'Oil Ull-t,.. 

..... 

.... 

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-- I ON O"'IU1l..., ... 0Ht -U .. 11. 

- .. l~igure 3.1·3 (C) Spectrum P'hotos28 GH~ 100 kf-17. RC$1lW Sitc2 at IOmAGL 

lllnrltsu OI.ID":OtlltO«ap= 

.... "''"' 

u• 

--

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.... 

-

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-

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-

-

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..... Figure3.1·3(D) Spcc1rum rholos 28 Gl·b;-IOOkH~ Res BW Site2 at 2m AGL 

Adjusted mc:asurement vuiUt..-s (dOml) sbown iJ' red 
58 


1025DANK44.eps

COI'I'OCIOd.tnQI2017 

/lnrttSU ~tJIIUO'e 

--... 

~ -

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-

-

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-·-

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-

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-· 

Pigure3.1·3 (E) Specumn r ho<o< 28011z - 100 kii7.RU BW Sitc3 at 10m AQllllnl1tsu ~trt•H»e 

!!!!....___ 

--

·

...... 

-

·

.... 

-

--··-tile .. 

® 1111- I 

--

.._ o.t..aOIII:t. - pn- n~ ~-+--~--+-~~-+--~--+---t-~~-~.-w:=~ 

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........ 

fir "' ~ ~+--;---+--~--+--;---+--~~ 

,_ n ............ 11 ~ 

,...i.gure 3.1·3 (f-') Spectrum Photos 28OHz· 100kHz Res BW Si1c 3 at 2m AGL 

Adjuslod measurement va1UC$ (d0tn1) shown in red 
59 


1025DANK45.eps

~412Cn017 

1

1 /lnrftsu WIWH1 , ., tJ .~~ e 

·... --

-;;;;;;---- ---..... 

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pu I" 

.... 

-·-

Piguro 3.1·3 (0) Spccttum Photoo 28 Ollz • 100 kllz Res BW Site 4 at 10m AOL 

·-... -

- .. -- ~ 6-~~M~t--1---t--1---t--1---t--1---1 = 1•llv 

p....- ;,.-+-t-+-1--t--t-t-+-1 

:;:n.. t=m- ··~ 

~ pmr ._.1---r--t--t--1---r--t--1--1 

p;-r- 116 

·-

-·- Y - u - ... ...... Pigure 3.1 -3 (H)Spcctrum J>ho1os28 (Uiz - 100 kHz Res BW Site4 at 2m AGL 

Adj\l$ted l'l'le.'iSllrcment v11lues (dBm,) shown in rod 
60 


1025DANK46.eps

CortecCiM .12tnt'f1 

l11nrttsu tl~Wl'tlttlct•te 

Mtll'll Ml ... .,, ••:t.m .U41-IG-O 

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-

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i:;u;; ,,.,.-

o.wr•.zu•GN~~ 

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Figure l.J-3 (l) Spectrum Pbocos 28GH~ .. 100 kl-lz Rc;J BW ~i c.S at 10m ACL 

IArwtsu WWtOtr ttM t:,. ld 1111- I 

.."".. '~ 

.... .... -

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-

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~ 

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.. 

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-...-

-

---- c.w:uu•GH• 

..... ........... 

,.""~ 

r OH ou:Utr

.....,... 41U54~ I .n.~ .,.... --- Figure 3.1 ·3 (J) Spcctrom Pho<os28 Gl·lz-IOOkJI>.Res DWS;te Sat 2m AGL. 

Adjusted measuren1cn1 values {d6m1) shown in red 
61 


1025DANK47.eps

Corrected 41'2<1t2'017 

,llliYiw ~,, ~~~,. 

..... """' 

,...,_ ...... .... 

!:!L,__ 

-

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.. Figut< 3. 1·3 (K)Speotrum Pho<os28GHz·IOO kHz Res AW Si<e6at IOmAOL 

lllnrltSIJ~''N*•le ljlJ 1111 • ·• I .... 

,.,.. .... .... 

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pn -~--~-t--t--t--t--t--t--t--1.--.::_~ 

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pu 

F, -+--t--t-+-+-+--+--+--1 

II- I 

- ... 

..... ---·---·-

Figuro3.1 ·3 (L)Spectrom l'hooos28Giiz· 100 I<HzReoi.IW Site6ao2m AGL. 

Adjt~1cd measurement values (dDm,) shown in red 
62 


1025DANK48.eps

~4tl!Dt2Cit7 

1/IIVft'SUot,.o,rm•,.,_•,...,,. 

..... .... -

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Figure3.1·3(M) Spectnun Photos 28 (iH7-- IOOklh: Res BW Site 7 at 10m AGL 

l/lrv'ltsu~71UIIIe 

... ,~ 

- ..... 

..... _ ... 

!!!!....____ 

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--- Figu,..3.1-3 (N) Spectrum PbC>too28 Gflt · 100kHz Res OW Sito7 at 2m AGL 

Adju..<i:tcd mc~surcment vahiC$ (dBtn:~) shown in red 
63 


1025DANK49.eps

~41'21Wl017 

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.

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,., II 

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Fit:uro 3.1·3 (0) Spectrum Photos28 GHz· 100 kllz Res BW Site hi 10m AG~ 

I/IIW'tSUOb'Oit'n,,CII',,....,e 

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-

.., .. _ 

l'igwe3.1·3 (P) Spcctrom Ptootos28GHz · IOOkH7.RC$ R\V Site S at2m AGl. 

Adjusted mcasuremer1t values (dBm1) shown in red 
64 


1025DANK50.eps

·... --

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·..... -.... 

--.!!:.,..._ 

---~ 

....... 

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l:;n m 

-- 1 ON MJ" H11Hd'_,.OHI --&tl . .. 

'"" I ,....... II $pWI .. Figure3.1·3 (Q)Spoctrum Photcn 28 GHz- 100 kHz Res BW Sitc9 at 10m AOL 

,..,.AI ... ... 

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Ao.lllla -

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t ON ot'F2eJll"'J .... CHr •N»• 

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--~ -

l' igurc 3.1-3 (R)Speetrum PhotM28 Gllz- 100 kllzRc:sDW Sitc9 at2mAGI. 

Adjusted measurement value.'! (dBrn.) shown in rod 
65 


1025DANK51.eps

Comc;tcd 41.1:0t201, 

1./WW'RSU~l~.»e 

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figure3.1·3 (S) Speclnlm Photos 280Hz- 100 kHtRt.:s BW Site 10 at 10m AOL 

JvwRsu~ltUth,. 

..... 

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-

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--

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--

Figure3. 1-3 (l)Spoctrum Photos 280Uz • 100 kJrz.Res BWSilc 10 at2mAGL 

Adjusted .neasurernent vnlues (dllm1) showo in red 
66 


1025DANK52.eps

eon.dld41201'2017 

l/lrVltsu OlJIWCIIJ~ne 

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.... 

Figure 3.1-3 (U)Spectrum Photos 28 Gil<· 100 kHtR<>IlW Site t 1 at 10m AOL-82 

........ _ 

·... --

--.... 

·

...... 

-

·-.... 

~ --

~ -

_., .. ~ 

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Hgu,..3.1·3 (V)Speetrum Photo.28 GHz- 100 kll<Res DW Site II ot2on AGL 

Adjusacd measurement values (dTlnlt') sho\YTI in red 
67 


1025DANK54.eps

SEC'MON4 

SUMMARY OF RF$lJLTS 

The results of the mc--asurcmcnls oon.ducted al the ViaSal, Inc trunsmil site in Carlsbad, CA are 

presented in this section. 

The tables on the next page contain the dat:. collected during lhe RF Mcasu:remcnls on February 

14,2017. 
68 


1025DANK55.eps

Tablt 4.1 

01r. frotD RP i\lttsa"'"-•" •• 10• Allo~• Ctoud Lt''tl 

·r.bJt ... z Daca fro• RF Mtti•ttatlllts at l• Abo,-. Crou 4 IA\·tl 

..,_ '-*I- --n _,,. ,, __ , __ -- -- . 

it 

ji: 
69 


1025DANK57.eps

SECTIONS 

CONCLUSIONS 

S.l~ 

Mcasu~ ble signals above the measurement system's noise Uoor were obStrvc:d at Lest sites 1 

through 6 at I 0 meters AGL. No •noasumblc sigoals were observed above the measurement 

system's noise noor at sites 7 through II at I 0 meters AGt.. 

Mcasurcablc signals above lhe measurement system•s noise floor were observed at test sites Sand 

6 at 2 meters AGL. No mea.wreable sjgnals were observed above the measurement sysrcm's: noise 

floor at all oilier sites 3.t 2 meters AGI.. 

The highest observed signal WliS -103.25 dllm (-133.25 dDW) at site 4 at 10 meters AGL. 

The values measured in this repOrt are inlended for use by ViaSat for incorporation into a larger 

analysis whore ViaSat will pt:rform the rlecessary calculations to convert the measured signals in 

d.Bm (dOW) to an cquivalerlt power flux. density in dBm/(m1*MI fz) and to determine. where 

possib ~ the effective signal attenuation over and above rrec space loss. As an clemenl of a larger 

analysis~ infonnation in t11is report i.s nol intended lObe used on a standalone basis. 
70 

Report prepared by Roberson and Associates 

Filed with FCC September 25, 2017, GN Docket No. 14–177. 


1025DANK59.eps
71 


1025DANK60.eps

1 EXECUTIVE SUMMARY 

This analysis or a l)'pic-'1 deployment scenario show!i that small Fixed Service llite (1-"SS) 

Earth StaHons (ES) with uplink tmnsmi»ions between 117.2-S.0.2 and 50.4-52.4 G Hz 

oommunicating with g«>5~ado ary--orbil $paOI:Cr.d'l can be located in the $ante urOOn ai'CM as 

FiJth-Genemtloo (SG) wireltss Base Scations CBS} withoul the need foe cOOtdinalion.' 

The analysis utili7.c.:s s1andn.rd methodologies, parumeters, metric~ and models, extended and 

supplcmen(cd as nocessary to support the specific ~ettario under study. 

The primal)' coexistMCC metric utilized is the mlio of 1-""SS t:.~ received power density (I.,J 10 

noise 000l' power <ktlsity (tl~ at the. 5G OS demoduJmor inpc.•t. or /,Jfl,.. This metric is used to 

determine~. 984l. and 95% probability geo&raphic oontoucs for 1./ft,. s ·6 dB. 

'the ballcline confidence pi"'bability contour data b;u beef) evatualed with respect to absolute area, 

a.ld a lso is described by way of ex.amJ>I-o with respect to a specific urOOn region (i.e .• Cook 

County, Illinois). The res:ulls indlattc that any area where pocentitll C()t;(istence issues exist is 

\'Cry small, and the c~~~ of such fl circumstance actually arising in any given rt<lJ.wor1d 

deployment is e.xtn.:.mely small. 

11M! repor1ed tOUll 99% confidence probabilily QOntour area for 1,/Tl., ~ -6 dB i..'i less than 0.0036 

km2 , and the 98*' oontour IC$$ than 0.()0().12 m~. wbich conSti!Ute les.s than 0.00009% and 

0 .00001 " of Cool: Coumy. respoctively. Funhennort,the ovetall probability likelihood ch:u an 

iodh·1duai5G I3S will actually e;~peritnce IJrl~ > ·6 d6 is only 0.24~ or n.pJl'f'OXimntely 1 ch:fmcc 

io416. Thus-. the results or this analysis sbO\v thai ()()C:dste:ucc betw·cen f·'SS ESs and SG OS$ is 

feasible without the need for coordination. 

o~ab y, these rcsuhs are ba.'icd 011 constrvalive 3$.turnptions, including p<Uh loss. use of peak 

side lobes (instead or actual lower values at different otT-axis angles). considering only ns a •lfcnnas with essentially omni-dinx:tional coverage, calculating much-higher <.'()ntidencc levcls 

ror n..'<lcivcd power density than commonly ulOCd, not accounting ror 3Jtenuadon from roor blockage, assuming all ..outdoor SG deployment . .-.od n¢ver oortsidcring tho opemtioo of au ES at 

an elevation angle aOOve a minitMI vah~e. 

Moreover, the foregoing calculations do llOI take into account the mitigating effe<::L'I ()( Olber 

facio!'$. such :u (i) inherent 50 BS antenna array techniques: de\·clopcd to allow SG systeons to 

rope with self-hnerference and interl'e.reoce between olbcr 50 S)'Stcms. or (ii) FSS F.S physic:ll 

isolation, both of which would virtunJiy eliminate the chance of a rettl·world problem e.,.er 

actually ari$ing. 

1 Note ·n~e ttf:uh• or th¥ ~lysis depend on the cltsn~tlr$ of 10.: ftlf'lblr S)'SlMI t.t .,~: the 

n11CI1~~o~>dol(l$p' lC.dity CbUld be tpplkd co 4)'tt<ett'l$ ..-ith od~e:1 atdlit«:tl)tcll 01 fol,~l..-oofC~r.ttioos.. 

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2 SPECTRUM COEXISTENCE SCENARIO 

2. 1 Overview 

1"his an3ly5>is provides t1 tectmic.al asses.smerat for the case of a small Fixed Service Satcllitc (FSS) 

Earth Stati<>•1 (ES) transmitting to a spacec-raft in gCQSttuionary orbit, :tnd located ncar a 1-iObGeoernOOn wirclc.:ss (SG) Oase Station (H$). The MScssment scenario under study is shOwn in 

1he following figure. 

Key: 

., FSSES 

(<•·•>) l 5GBS 

Figu(e 1. Spectrum Coexistence scenario 

The ptimary ooex st~ cc metric utili1,cd is the ratio ol ~SS f.S roccived power density (I~J to 

noise 000f power dcttsity (ru.J nt Lhe 5Ci JJS demodulator input, or ~/11 111 • The S.J)OCj(ic speclr\lnl 

ofinte""' ;, the QN oonds (Le •• 47.2-SO.Z and 50.4-S2A Gtlz). 

This assessment utilit.es s.t<'!ndard methodologies. patamcttJS, metries and models lQ tbe greateost 

possible exlent. Where ·~ry these resources were e,x_tended/s-upplemcntcd to suppoft the 

specifics<.:eoorio understudy. Primary souroe.c; ror this wnrkc-.tn bt round in II HI IJ. 

The following $001ioos describe the key oomponents or this: an.i.lysis. 

2.2 FSS ES System 

The inform;~tioo in this $<..'Ction on I-SS ES $)'Siem deployment and J)O}r'ameters: was provided by 

ViaS:n. 

2.2.1 General Description 

The rss ES system uses an offset fed pambolic refle<::tor antenna of a1,proximate 1.8-mcccr 

diameler. h (;Ill be in$1.nllcd using truund mounts or on existing structures such BS building roofs. 

The antwna boresig_ht is pOiutod at a notrdnal vertical elevation angle or between 35 Md 55 

degree.~ relative to the horb.on as didated by 1he orbital loc::acion of the carg.et s:uellite. 

Tbe power amplified (PA) Oulput in this 5tudy is lY),icolly7.l.S milliwatt$ per right aDd left haod 

circular polariuation (or cact1 1 Mllzof modulated bandwidth. 
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2.2.2 ES Antenna Pattern 

To determine lhe f:-.S anlcnna pGmmeters ncoded for this study, an antenna being developed for 

this application was modetcd by ViaSat. The design is lxtscd on a commercially a"ail3blc 

renector. When hl opcmtion !be es nntcnn.1 is poinled .s bsta nti;~lly upward in elevation and mU$t 

Mvc ~r view of the sky in the direction of Ute target satellite. In otdcr to rwess the intc.raction 

with tcrre.<>Lrial SG systems, the F.S ttnlentut gain well off the main beam is ot primary interest 

'fbe ES antet~ na pc:rfonuanc:e. data indtc:ue tl'l3l for 10 to 90 deg.rees from the main beam, lhe side 

lobe peaks plotted in dB as a tunctton of angle are a strnig.ht line. This follows the process: Qf 

M.IS..SJ Table S 12J, Other literature (i .e., ECC P"rl 154 IJJ) show.s scveml ex.amples <tf a 

reflector <lr:ICenna with similar side lobe t'(Sponsc. Therefore, I he following .side lobe mask 35 a 

fuuc.Uon of the angular distance from the maln beam i$ appropriate. 

GAIN .. (a)=-5-afJ (IO"sas90') 

= ·35 (Ot>90') 

(1. lhearcdistancc to the main bel•m (not defined (Qr~ < 10'? 

The rouowing figure plots the 1\&.~k or 13quMion ( I). 

Figure 2. FSS ES Antenna Mask 

'J'hc choioe to u.se a mask nt:t.tcbiug tJI(; pe.tks (as opposed to the averages of the ripple) is 

conservative and ignores lhc possibility or lower sidelobes below this J)t.1'k value in the final 

notcnna design. However. this mask is more rcOectivc of actual peffonnancc, eompalt)(( with the 

2.5.209 mask l4J, which documents an upper bound regulatory limh . 

2.3 5G BS System 

2.3. 1 General Description 

The ba...<oelinc deployment scenario used is described a'i the "Outdoor Urt)<).n bolspOt .. in ·ruble 12 

(Oep oyment ~la ed pa.rtuuettrs for baOOS between 45.5 GHzand 52.6 Olh) of tSJ. ·rl'ltso IMT· 

4 

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2020 parwnctcrS were specified by lbC ri'U 171 "to be used in ari g and OOffiiKltibility Studk:$ 

ror bands betw¢t,:n 24.25 and 86 GHz.'' 

• Antenna heighl (mdialion center): 6 m (abOve ground level) 

• I)Own-lilL: 10"' 

• Below rooftop ba-:c S&ation antenna dcp!oymcm 

• Antenna polari1..e.tioo: Linear %4.)0 

• ll orit.otttal/Vertict~l tadi:lling clement spacing; 05 of wavelength (or both HN 

• S:x 16 antenna array COilfigumtion 

Continuing use()( LS). we ha\·C selec.OO the BS Noise Figure to be 12 dB 1\S specified in the 

5(:cond table contained in Scc.tion 3 .. System rda.tcd pammetcrs," column '"37-52.6 Oflz" (row 

S.l). 

2.3.2 BS Antenna Pattern 

Since there art no <:ommeroial examples <I SO BS antennas in this band, a pr.lCtiC31, conservative 

antenna pcrfonn!lnce model was needed. Using n.'H;.thods similar to M.2 101 IS), the gain m.tl$.k 

was determined from the thlxlretleal lincar army. An 8-etcmcn! vertical by 16-clemenl horizontal 

rurot~s.cme l was assumed as it t'ppcars oommooly in ll1e literaaure. 

Tbe tht<>retic<ll deriYation or d.e normaJiU>d gain or a linear array is widely aYailable. ro.r example, 161 scc:lion 3. Equation 13.21 giYes the normaliud gain function with steering and 

uniform illumination. r'()r this ~Miysis:, a broadsidt: beam (i.e., no steering phase stlil't) with 'JJ2 

eJcmen1 spacing i$ assumed. This resldts in the following eq-u3tion. 

Where: 

rrsin,P 

elevation angle ubove I he mnin bcJun 

(2) 
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As the first side-·lol>e (or U1is ve11i~l configuration has a peak at :lJ>I)f'();\imntcly -13.3 dB. tbe 

mask was chosen to follow the lhcorctic.:nJ value of the main lobe but limit the. side--lobes to · l3.3 

dO. Ll«ausc tbis an3lysi'i will be mosc §ICASitive to the sldelobo levels, the relatively small 

oootribution of the clement gain wos not includ¢<1. The pet'k gain is the product ot the number of 

clements,so rortbc8AI6 army is 101og10(1Z8) or21 dO :.\deled to the norn\31i?.cd pattern. 

In a sim.ila.r manner. the horizonml p in or the SG l3S anh!nna is modeled based on a regular army 

of sixteen hori'l'..otual elements. •rtlis se•ves to nruTQw the main lobe of the paw!nl ver1us that of 

lhe 'I'Crtlcal 1)011ern. The relath•e gain in tile h0ri1.ont.1t paucrn is shown in Figu~ 4 below forM 

assumed 120-dcgrcc &t'lCtored antenna, It Is this pattern that will be used in detennining the: 

rehuive gain of the so as as the anll!nna is rotatcd to differtnt nl.ndomi'Zed orientations. pe-r the 

methodology c:ct>lained in Seclion 3.1.1 . 'to simplify lbe analysis, a "block mask'" of the pall~m 

is employod, in which the relative gains or tbe m..Un lobe (defined by the 3 dll beam width) and 

side lobts" are cons:uuu as a function of angle. As wi!h the elevation ~uern. the relative &ain in 

the side--lobes used in the nn:dysis is t~Jso -13.3 dll. This approach is COilW"Vative. as it reflceiS 

the. peak gnios of the respective lobes. and does not ra<:e.or in cbe lower actual gain of the s-ldc 

Iobeii and the assocl:ued nulls, as depicted io Figure4. 

Unear~ ~Galn 

N.:16 

.....- .... --:;o-m-.. ---------------, ~ i --------------· 

lf\("'1\1\1\ "'I 1\{\f\(\f\ 

I' ~ :1 r ' J 

Figure 4. SG BS Azimuthal Antenna Pattern wHh Block Mask 

2.4 Coexistence Metric 

The primary coexistence: metric utilized is the rotio or FSS 6S rcoe.ivcd power density(/ .. ) to 

noi5e rtoor power dc.n:;ity (ft.J at Lhe SG DS demodulator inpu•. or li/'1., (dH). The folli)'l·ting 

two sections describe the owtric threshold selection and deOne the coexistence metric 

oomponents. 

2.4. 1 Threshold Selection 

Received power rrom M ""'SS ES is a"-!ie.'ued . ns QCC:eptablt. ir 1../•lk s ·6 dB. 

The --6 dB 1,/'1 ... lhn::shold at the.$(; US demodulator input \~$ sclocted IO confOfnl wil.b an 11'-' 

Worl\ing Party SO liaison to Task Group S/1 for S<i S)'"$1Cm J'rok:Ction "'lrres~ctiwt of the 

rJUJnbef (Jj Ct/Ls <J!fd 111dtpe1rd~nl Oj the number Oj inUrjercrs" r11. TidS lbreShOid iS qu,ile 

cooserva1ivc. The SG BS rooeivers are expocted to be: ioterl"erenco-limil4.-d becu.~ .SO i.s a multi· u~• :,.y.!>ltml. l>owe, ~~etved from otb<:r SO co-<;hMnGI tn~mi$Jion:~ will lik~ y be much hi&h¢r 
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than receiver noise power Tl•· Received l-"SS ES powt'-r nt 6 dB below the noise floor will cause o 

negligible increase in total received undes:ired pow¢1 given the prcs<:.nco of 5G co-channel 

tr1lltSmis.sioi'IS. ln other words, a more realistic as,.<;cs,c;mcot of S(; receiver perfonnance would 

utilize I J ir:tJ (where lr:o is the c<H.":hannel, same-system interference power dell$ity), which would 

produce more favor<~b e. n:sulL~ with respect to coexistence or FSS ES and 5G BS in rcal-wortd 

sccnarius. 

2.4.2 Component Definitions 

2.4.2. 1 Noise Power Density 

'fhe SOBS noi.se Ooor power denS:ity Crt..> is deft nod as follows: 

'llta = -204 + NFt~s 

rt.. 5G BS noise floor power density at the demodulator inJ)Ut 

(dllW/IIz) 

- 204 Absolute noise floor (1(]'8) power density (dllW/Hz) 

NF,. Noise J'igureohhc 5G BS (dB) 

2.4. 2. 2 ReC6ived Power Density 

Tbc ..-ss US rcoeivedpowcrdensity (!, ) ls defiood as follows: 

Whcro: 

d 

Received power density of lhc FSS ES al d>e SG BS 

demodulator input (ctBW/IIz) 

Transmit power density of !he I'SS r,s (dBW/IIz) 

Antenna gain of lhe F-'SS ES in the l)~.imUIIlal (0) and e!cvalion 

(t) direclioos of lbeSG BS (dlli) 

Antenna gain of lhe SG ns in lite nozhnulhaJ (0) a1'd elcvatiOil 

(tl directions of !be I'SS ElS (dOi) 

Polarization gain between the ES and BS anlennas (dR) 

Palh loss b<:tween the FSS I'S and SO BS (incl. fa<fing and 

deploymem factors, dB) 

Threc-dimensiooaJ dis(ance bel ween the ES and ns antenna 

locations (m) 

(3) 

(4) 
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2.5 Propagation Model 

We have i.rnplementcd path loss models ..coording to the methods dcsetibed in lhc mO&t ~cnl 

versions of 3GJ)P TR 38.900 lJ O]. This document is lnrgely cquh·alcnt to ETSI ·rR 138.900. 

''Study on Channel model f« frequency spectrum above 6 Gl-1:.(' II I J. 1'IIC3C documents describe 

pf"()JXl.gation models to tJco. used in cvalwlling 50 syStems at frequencies from 6 to 100 GHz. 

The rolevanl sccn3riOS include ··ul'ban Micro---Stree1 Carl)'On" (U i~SC) and .. Urban Macro" 

(UMa), described in sections 6.2 and 7.2 of these documenlS. The UMi·SC model penains to 

situations where 50 RSs. are deployed below the roofrop len!b or surroMding buildings. while 

UMa oorn.:sponds to llSs dCJ'loyOO above rooflop IC\'els. 

2.5.1 Median Path Loss 

1-Qr the UMi-SC and UMa scenarios, the pncl• losses arc charactcri't-cd io lcrms or st1s or equations for lbe median path loss a<> functions or lhe 20 distance bel ween DS a.nd Use.rTenninaJ (llf), the hcights above ground of the SS and U1' ante.tu'lae, Md tho «.ntcr freqoency of 

cmnsmi$SiQn. Foe each of the two scenarios, the.re ate equations for LOS and NLOS path losses 

(pertainin& to cases where there is or is not :a line-of-sight between lhe OS and lfr tent~ae). 

EquatiOI'IS ror the prob;lbilily of bclng LOS an! nl.so provided ror each scenario, which {lf'C a 

function Qf the 20 distance. 

Values for an eAtUnpfe set of input para.netei'S are shown in 1-"igure 5. Throe curves are included, 

th<l$e being LOS, NLOS,a.nd Combined median path loss. TtteCombiood curve i.s lhesum of the 

L.OS and NLOS C\trve:s weighted by the respective probabilities of the txuh being LOS or NLOS. 

L_ I "• - O. t»U, ... J 

Figures. UMa Model Meenan Propagation LOst Curves 

2.5.2 Log-Normal Shadowing 

Tht moc:kls also include additive terms (in dO) to accotnmodatc for stali.stical variation d the 

path loss to n::flect location vtu'iability d~ to shadow fading.. which is modeled a<x:ording to a 

k>g-nonnal disuibuUon (i.e . normal in dl)s), wilh a specified s!Mdard dcvlatioo ror each scenario 

•nd lOSINtOS cose. 

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Figure 6 sbows example Probabiti1y Oensity runctions (POFs) for a SJ>ecifi~ sc;1 of model input 

par.tmelers. 'f hree POF rvcs arc included,tbose behlg LOS. NLOS,and Combined path loss. 

'rhe Combined curve is the sum of the LOS and Nl..OS curves weighted by u.e respective 

probabilities of the path being LOS or NI..OS. Note that the LOS and NLOS curves tu.lve 

symm~tric nonnally distributed POt·s while the Combined curve, being tt weighlcd sum ar the 

two C()n.$Lituent Nurmll cur,·es. does ocx. 

~'\ / \ 

I \ .. , : .' ~ .. \ l 1 I\·, \ 

i ·' ,' ' ~ - -c-....... 

. ' \ \ /,,.,/ \ "'·~ 

L 

~ -~ . ______ ;:.-,.._ .0 90 ~ 

~w..loss(lll ! j Figure 6. UMa MOdel Path Loss PDFs for a Gtven Ofst.ance 

1'he:sc POF$ \Viii be used in the technical analysi$ to model probabUislic p1Uh loss, s-pcdficnlly to 

dclcrmine the J:nob;tbHity that. at a given distance. the path loss will ex~ccd the value necessary 10 

achieve ldll•·• -6 dO. 

figure 7 showJ; lhe Cumulative Distribution FunetiolU (CDFs) associated with the POF's of 

Figure6. 

Figure 7. UMa P-\Odcl Path L0$1 COFs for a Given Olstance 
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2.5.3 Path Loss Confidence Curves 

The model can also be used to calculate path loss conOdenoe cun·es. lf a oonfidei)CC value is 

specificd,5a)' X%,the j)Qih lo.."!l value for w'hich lhcce i.s a X% protx.bilityC)(bcinggreater than or 

equal loa.;; a funclion of di~anoe can be dctcnnincd. f-igure 8 shows two 1Jtl.lh loss wnnden« 

cun·es (i.e .• for 50% aDd 95'* oonfidcnce value.'i). 

•' 0 ~ ~ ~ - ~ * • - - • • ........... Figure 8 . Exomple Polh Loss Confidence Curves 

Tltus,at a dislance of 500 m,there is a .SOC.. Iiketlhood that the (XUh loss will be~ ISO dB and a 

95% likelihOod of being~ 137 dO. 1'his path loss mcchodo!Qgy will be U$Cd in lhc analysis to 

generate conOdence turves for I.JT't.,. :; ·6 dR. 

2.6 System Description 

A specific instance of the system under analysis is shown in Figure 9. Note lhatthc environment 

is urbnn. The l•'SS es atuenn.'l Is located on lhe roof or a building (height 25 m, which is the 

recommended vatoo forh81 in theulili7.cd UMa pmpasntion model (l lJ)that is taller Lhan most of 

the surrounding s.1ructur<:$. The SO OS antenna is loc:ucd below lhe rooftops of tb~ suJ1"00nding 

bvildine,1 (height 6 m). The SG OS is placed •<around 1he. comer" relative to the ~S ES building 

to ir1dicate that NLOS propagation is a po$>"1iblecasc. 

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Addilional details for tbe FSS ES M<l SO BS chamcteristi<:S/p:arumeters can be footJd in sections 

2.2 Md 2.3,1'CSpccliVcly, 

llflscd on tbis 'Y'tem dcfinilion, we havl-l selected the .. UrtxlJl Macro" (UMa) pr<>IJSgntion mQ<k:.l 

1 I OJ. T he FSS Jl() ay~ the role or lhe .. US" and the SG U.S as Lhc .. u ... •• as defined in the UMa 

model . 1'his is done boc.'luse. the UM:t "6S"' is defined as tbe devloc dutt i.s above surrounding 

rooftops while the UMa '"lfl". is defiJ1ed to be below the rooftops. 

In a LOS scenario, the hit;hly unlikely ••worst casc1' antenna oonfigur.stion is that Lhe boresigbts of 

both antennas are directly poitKcd at OI)C (U~Ih<:r. We will allow the 6S to be locmed alo11g 1he 

full 36<r ai'Qund the fixocl (in elevation and aJ".imuth) BS. At em:h BS location, we will evaluate 

pecformanoe over the 360' range of random lrt.imutha1 BS antenna orienLiHk>ns. 

3 TECHNICAL ANALYSIS 

3. 1 Methodology 

3. 1. 1 General OveNiew 

f-igure 10 shows a simplified view or the analy.si! mclhodolc>gy. J{ornll that we have preYiously 

SJ>OOifi<:d nocc::s:sary sySt<:-1n p;~rarneters such M antenna heighl$. elcv3tion angle:s. etc .. which are 

3Ssumcd to be in place. 

We cvaJw.te Ute poMibility that the SO OS may be j)lac«J at di(ferent locations nround lhe f-'SS 

E.~. while the £.~ i:t at a lixcd location with Ill fi:\cd antenna dirn.'tion. 'fhe Mgle 9 is used to 

denote cbcanglcol the BS'sJocation with respect to lhc F.S; 6 is defined to bcC!'when the$0 8S 

is Jocated l11lhe az.imuthal directio'' of 1he bottS"lght or the FSS ES aocenna. 

Additionally. the azimu1hal direction of the antenna or the US is ccvalualcd as being randomly 

oriented over a 3<iO degree mngc with respect 10 the ..:.S. The HS antenna is assumed to comprise 

three $CC(on:d antennae. each with a beam (;l);p3biC o( bein& sc~un<:d over 120 degrees. so th."lt :IS 

1ho US antenrru is rotated in a mndom direccion over 360 degtees the ES will always be within a 

scclor's bcamwidlb. 

This: assumption is conscrvutivc,as a. more likely case wouJd hnve Only a single sectored :lntcnna, 

in whicl1 C<'l'le the BS oould be l()(;atod in the OS anttnna's bacl(.lobe for many orien~Uft:w\S. This 

more rc:alistic aMumpcion would result in two prim:1ry consequences. one, in moot cases even i( 

the US antenm• islooa.ing toward the BS antenna it wiJI noc be: located within the main be.-un or the f:.S antenraa. and two. often the bnck lobe or the OS antenna will be oriented towal'd the CS 

amenn;1, 

Thi$ often will be the caw because the ES will be oriented in a wuthcrly direction toward the 

gcQSt:Uionary Ol'bital plane over the equator, and moss OSs c.:an be expected lobe located outside 

the I'WY'OW main lobe of lhe ES antenna. 

Convel1dy, 11~ probability of the 6S being in the HS antenna's main fobc.ns OPPQ5(-'d 10 n side 

lobe, i.s based on the relative betlmwidth or Lhc main lobe with respect to that of the sidc·lobc. as 

shown h• l;ig:ure 4. 

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As the 50 BS is placed at difTc.ront angle.s around the .ES.lhe value of d for wbit.h I,jq._ ~ ·6 dB 

at a specified confidence level (X%) is c.ttloulatiXJ. 'fhe set of tbe!le points 0\'Cr 360' arou.,d the 

f::S create$ the probability c:oniOfJr. The red shaded region indic:ttcs where a S(i BS plooemenc 

would result in 1,/'lw s .. 6 d B at less thsn, and the green region where /,/11 .. ~ -6 dl3 at greater 

than the specified oonfidcoce value (X%). 

Thus. the te.'l-ults of this ~ulalys s methodology enable insight into t.he sensitivily ()( SG OS 

plaoerncnt in the region of a FSS F.$. ·rhe smaller the rod r'C£i-on. tlle less $1Ct1Sltive lhe SG BS is 

10 placement. 

We will c-.tleuhtte the probability oontour using X=~. 98% and 95%, tbat i.s. the l,.frl. will not 

c::Jiooc:d the ·6 dB thi"C:Sh()!d at d~l dbtnnoc with th~c oonfidcnoe levels. The oonfi<tcnoe leveJs 

rue ba.'ied in tum on the statislj~ disu•ibution of the rocch·cd J>OWCr density at the specified 

disc~mee. The statinical variability from which this distribution arises is due to two variubility 

faC:IOI'$: ( 1) the lot;-normal variation of the JX!!lh loss aroUJkl the calculrued median path los:s, as 

c:..xplainod in Section 2.S.2.Md (2) the probabUilyor the ES being in the m3in lobeorside-IOOcor 

U'IC SG BS as it is orienled in rnndom directiQO$. as eXpll)in<:d nbbve. 

3.1.2 Assumption Discussion 

TI1roog.bout Lhe analysil, attemptS have been m-nde co use reason<\bly consetvath·e assumptions 

whenever possible in oons:trueting the coe.xiSICI'ICC· model. particulruty for cases where chcre might 

be unce.rtainty In ac.1ual deployments of FSS and 5G systems (especially for SG, for which no 

actual deployments CJ..i51). Suc:h conscrvnlive a;;sumptlons include: 

The lot:alion or the F..S nt n relatively high elevation,Md the subsequent usc of the Urban 

MacfQCcll path loss model (IJ Ma). which provide$ lowel' path loss values dl,'\n lbe Urbon 

MieroooiJ model (UMi- SC), for both I.OS :tnd NI.OS cttscs: 

The modeling of tbe OS and P.S antenna based oo the peak values of the side-lobes, as 

oppo...OO to, for example, ttvernge side-lobe ga ns~ 

The assumption or 3-stecored US antennas whict• provide essemially omni-directional 

OOVetagc, as Opposed tO Siflgle-$CCU)red antennae fOr which an J!S might be located in the 

Jow•£Ain bAdt..-IQbc:.J~ Not~tb y thi;s an~a )'3i:o~ doe:t uot consider lhe 1ypes or ne1worl< 

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archi1ec1ures thac might be: employed ror (llher types or SO eploymen ~ ~uch as fixed· 

wireless applica\iO!JS tlwl would not u.<;e an omni-dirotdonal antCJUla: 

The use of 99%. 98%, and 95~ confidence levels for assessment of rc:«ivod power density levels, wilh the 99% and 98% being ClUrcmely conscrvaliYe 1:\S C(lmp;trcd 10 the 

Ill ready OOc'ls.ervath·e. 95% protection target used in t9J; 

fhe as.sutnpUon in the OO.selinc analysis that there is no addicional path los.<~ aucnuallon 

due to shadowing from rooftOp deploymcn1s. whictl would provide substantial additioonJ 

auenuation of t-::S signals In the areas eiOOCf in to the 6S loattion; 

• The assumption that the SO OS sites are loaned outdOOfS when, pardcularly tU d~ high 

frcq•M.:ncfes in qu~ti on, indoor deployments might dominate: and 

The assumplion th3lthe t-:S eiCVfltl<>n onglt. i$ ~~a nthlirnal vah~ of 3S degrees. while the 

elevnlion could CAtend up h> SS de&rces. 

3.1.3 Mathematical Formulation 

lr we substitute equations (3) and (4) for f.)rt., (in dB) the rcsulling co ite expression is: 

Nocc that in this formulation we have cxplicilly a~nlcd for the fact that the elevation angle (t) 

:u which we must evaluate the FSS ES and 50 BS a ntenna pat.tefns are f\mctions of the clislaooe 

be1ween these ootcnnas (d). Thus. given a spetWed I.Jrl., vo\100 (e.g •• .-6 <18), we a1n $01ve for 

the disttr.oe (d) at which the antenna gains: and ptopagatio11 loss sum co the required Yah)C. That 

is: 

Note that :Ill or the values to the lefc of tbe equal sign in cquntion (6) me defined constan~S a.;; 

shown in Titbit I. 

KAtloot I:SS ES '"'"'v"'d JIO'o'W ck•hy (ll'.t} 1o SO RS Mlisc floor power llnul1ty 

(l'lh) 11 the de:modnlalor iurut (dB) 

p.;,alltb;t.tio~t pin btt'A'«II lile f.S and 8S I IICI!III'IU {dO)~~ .. ~ ((I( WP90f'~~~ 

rtrctcnn:l 

Tebte 1. Con51ant Parameter Oefln!Uons 

Substitution ofthe.'~e constant values results in the following equation. 

- 116.54 ~ c • .,._.<•> + c.,•.•<•> - ,.,_~n(d) 

·18A6 

11 

.J 

Tbc cvalllalion or equalion (6) has been implemented In an fucc:l spreOOshe<:t. 11tc path loss 

w lution u,.c~ the Combined (i.e, che wcishted C<lftlbinnlion or lh<~ 1.,.().~ a11d NI.OS O()mponenta) 

13 

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PDF to determine lbe solution for 3 specified confidence e~ el (e.g .• the Pl. has 3 95% proOObility 

d being greater than x}. as was discUSS«! in Section 2.52. 

3.2 Results 

1'he following resulcs pertain to a $Cl or syslcm pa,rnmcters :tnd models thlll wns chosen rrom key 

standards documenl'\ r7U8J. 

3.2.1 Baseline 

'f hc analysis methodology described in Section 3.1 was applied to the s.yStem as described in 

Section 2. For co vet~ encc, lhe FSS ES paranu ... 'tet$ discussed in Section22 are summari7,c:d in 

Table2, 

~r Amplir~rOulf"l' ~r4MP y per ri&ht and kH ••nod dreutarpoborintion ·1'8-.46 (dB Willi.) 

Table 2. FSS ES Parameter Summary 

The SG OS pur.m1ete:rs dlscussed ln ScctiOI) 2.3 are summarized in Table 3. 

ll<scrip«loo 

10' 

NIA 

8x l6 

•• 12 

Tabte 3. SG BS Parameter Summary 

I.:Or the selected pa ~ezs or TabiG I, Equatiou (7) show·s tbe ante.ina port to arueuna port 

oou:pHngloss needed to lcoep /~q., rom excee<Jjng the 6 dO tbteshokl is at least 116.54 dO. By 

oombinint; the sw.tistical varia.tioos of the path loss with those for the RS antenna gain variation 

d ue to 1'3ndom orienlation of U1e BS a1lmulb, lhc following figure is the coupling l<li>S al vt~.rio s 

conJidence levels ploued as a runetioo of separation distaoc:c. 

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l·· 

~. 

Figure 11. Antenna to Antenna CoopUng Loss conndence Curves 

Nole that at short sepO"tmtion di.stancc$, the clevntion angles are large and antenna l)attern I~ 

dominate so ror lhese parameters. the ooupling toss bas a mlnimwll level at 35 m. Sinoo only the 

99 mxl 98 percentile oonndence level curves have minhna bcJow tbe 116.54 dB threshold. only 

lhooe two will provide non· trivial data for the sub&tquc.nt analysis. 

figure 12 shows l.hc results of tbe above described ill\dlysis. Only pa.s.ilhe rol~tjon a.ngtcs are 

shOwn due to !ytnmeuy around 00. Tile .. Confidence Cut'\'c'' shows the distance that tileS(~ AS 

would 1>ee<l 10 be pi&Oed from the )<""SS fS in order to achieve the spccifaed 1,/rt., ~ ·6 dB 

<::OOfidencc level, 3bsent Ol)nSjderation of nny ot the other faclor5 discussed below. For example, 

for an angle 0 (soc S<:ruon 3.1.1) or 0' and • oonfidence l<:vcl of 99\{1, the SG 8S would r>e<d to 

be pl&eed ~t l~t 73 m from the FSS I?S to nchieve the spcci!iCI.I result, absent the mitiga:th~g 

cn'oclS of' other factors, such tli inhettn1 SG DS antt:-11.na atroy techniques. and FSS ES physical 

i.:<~O alion. as discussed in Soclions 3.3.1 roKI 3.3.2. Note that lhe 959ft pi()( i$ always 0 as 

explained above for t-igure II. 

_ .. i . , 

~:ll ~ .. ~ .. I : -~ .... 

l : 1.~-..L-------- ---

~: 

.. V.l\~loo~.-ft(( 

F'S)ure 12. Baseline Analysis Results 

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l~obn•sma IUld As.'\odatt'S, LLC • 

Altbougll t-igure 12 is useful for obtaining distance infon:nati<>o it does not pn>vide a spatial 

CQn e~t. ·this spatial COnlextual view is provided in Figure 13, which proje<:ts the diSI.tlllCC daU.. 

(rom t•igure 12 01110 a polar coordi~lte systtm. 

r----------------. 

Confidence Curves for 1.,/'la. S -6 dB 

DJ ... ~ ... ..........-

Figure 13. Baselfne Analytl-t Re-sutt.t: Polar Projec1Jon 

3.2.2 Coexistence Implications 

Note that the area encompassed by lhe ~ oontour is bounded by a rectangle or dimensions 

73x49 m. Ttl us. Lhe tolal area i.nside the 99% confidence curve iJiess thao 0.0036 km~, 

The sigJtll'ic:ance of a 0.0036 km' region can be assessed by comparison loa well-known urban 

county in which Wgh ca5X'City SO mrnW3ve BSs ooukl likely be deployed. thnt being 11:tc Cook 

Councy .IL. Cook County is the second largest in the l)nilcd States by population (20 10 Census). 

When .. Cook County, ll,." is cntcnXI into Coogle Maps, the tetumed region is sbown by lhe ligJu. 

red $haded area (see Agi.Jl'e 14), N()(c th:l.t the "Quick fact.'i·· Jcction indicates lhlttthc popuJalion 

i$ S.Z4 million and the area 423S km1 . 

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---·----- ---.... .. ._ ·---...... --- -·-

- =·- ·· -=--~-- 19 ~ --. .. ... . :-r • - :. ;;. ... - :- . . • -·-

.......... _ .. 

. -........... . . - . -· . ..:;:--_ - .- -r:..... -;;:· . .. .....,e 

Figut'O 14. Googlc Maps: Cook County, IL 

T'hcreforc. a 0..()036 km1 arta constitutes only O.Q()()()l)% or the Cook County ttrea. Were we to 

mnkc the simplirying tlSswnption or unifonn population density, lhe number or Cook County 

rts:idenLS livin& insicte the 99% oomoor is appro;dmalcl.)' 4.4. 

Note thai if we usc: the still cx1remcly COilSCrv:ltive 98~ contour the am~ is 0.00042 km1, which is 

O.OOOOt%ortJ•earea with only 0.5 rtsidentstiving inskle. 

'I hus, given the availability of FSS ES deploymern toeatio.a flell.ibillty. these e . ..:t.re1oely small 

foocprints clearly support succcssrut coe:<islenc;e. Note that this is a worsH::use result, a~ it 

neglects any improvements due 10 fSS f.iS antenna pbysieal isolation and SO antenna array 

techniqoos(sccSections 3.3.1 and 3~1 . 

3.3 Additional Mitigation Factors 

The rollowin,g two sections will discuss two likely mitigmion techniques, those bcin¥ f'SS t-:S 

l_)lly:;ic;ttl i501:ttion nnd SG OS anlenna army toohniquc.s. 

3.3.1 FSS ES Physical/solation 

f-igure IS sbows the geometric implications fur the ease in which the FSS ES antenna i!l mounced 

oo a modc:s.tly sized building. Noce that the 6S antenna is mowttcd 2m above the roor Qf a 23 m 

tall building, resulting in a 25m deployment height. Tbc 1:$ antenna is located at the roo( center, 

which is a J6x 16m square. 

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Robc.>~W~l aad A.~ates, l,LC • 

Figure IS. Geometry for Roof Blockage of FSS ES Signal 

Drawin& a line ftOcn the l!S antenn~ lhattangen1iaJiy touches 1be buikli.ng, we note lh.""tt a 50 BS 

antenna tbat is 6 m t'bove che gcound will ha\'c "line of sight" co the 'P.S ank:nna only at di~anocs 

grcaler tlw.n approximately 80 m. If the BS is located cl05t.r th.:tn 80 meters then we wOtJid ex poet 

significant si&nal attenuation due to blockage by the roof itself. A1\d,the closer the OS is 10 1be 

bvilding,chc greater 1he ttF. auenuation due to roof blockage. 

The FSS 1-.:s imtallation c:e..n be readily modified co provide additional l~ .F. isohtl.ioo to a SG BS. 

figure 16 shows the ca..w in which an R.F. t.ritJ Q( htighl O.S m bas been place On the roof edge 

in the bocesighl dirc<:tlon or the FSS ES antenna. 

Flgure 18. Geometry tor Roof Plus Barrier Blockage of FSS ES Signed 

Omwin& a line from the GS antenna that laogentially touclles the txarrier lop, we nole that a SO 

US antenna th~t is 6 m abo\'C the growld will have .. line of sight'' to the I3S antenna at a dis•ance 

ol3pproximntoly 118 m or greater. 

In an open area, as the US moves ci05Cr than 118 meteB 10 the building blockage loss i$ primarily 

dctermiood by diffracdon loss. The heit;.ht IXtr.unetetS used ill Figure l6 were used to cvalu:ut 

diffroctlon loss as a function of distance (2·0, ft01n the I3S antenna) at .SO Gfl7.. with the re3ulting 

data shown in Figure 171121. Noce that at a distance of 100 1n difrmctton loss is greater I han 7 

dB, :.ndat90 mover IS dH. l't1us.signifteant ttdditional diffraction 1-ossc.an be expected. 

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.... . in." 

:f-.e» s ' .... Yao.to ~ .a•'Gil 

Roberson and AJ>sod.atcs, U .C • 

Oiffr<K:tionloss ES at Onfef of Roof •. s m Bar~r 

'.,JOe-) "' 

Figure 17. Diffrac:llon Loss with a 0.5 m Barrier 

lncreaslag 1he OOuier height also increases to the ''line of tlg.ht .. disiMCe and resulting diffrac1iM 

loss a.t close· in distaooti"S. (;iven the directionality of tlte ES ;mtenna. the barrier needs only be 

instaJJed in the bc>rcsigbt antenl)a diroction. 

Ce:nahdy, scenarios CM be envisioned thm t'C$.Uh il'l lm favomble ~istenoe oonditiuns. f'Or 

cxample,thc .SO OS antc.nna height oould be incte3SC<I1o IOoreven 25 m.or th.e. FSS ES antenna 

could be IO<'.atcd off-center oo the roof. or the building could be shorter an<Vor l"ttam)wer. 

However, tht, above specific cases arc hueoded to demonstrate lhat C"cU'C(uJ selection or ES 

deployment cooditions caa significantly enhance the abillcy of aK! FSS ES to cOCAiS-1 with a BS. 

3.3.2 5G BS Antenna Array Techniques 

Sin(.-e it has direct and sj8n.ificant lmpac...'1 on system tapaeily and slnglc user tJm>oghput, 

int.erfe:rcncc mldgallo11 is a very activo area in SG research and sc.'l.ndatds. Many of the 1echniques 

developed ror SCi systems to cope with sear-inlerrmncc and interference between eo-existing 50 

$ystcm$ will provide an equal bentfit tg-.timlt other co-existing $YSiems, whether SO or not. In 

order to provide some context in the area, examples of ~ctivily in cacb or the. following classes 

arc diseus5Cd. 

3.3.2.1 Z&ro Forcing 

ZerO rore:ing is the 3D geuerali2:atlon of l'lull stoorin& in a clunerod local envimnmenL Since there 

are mull.i.plc, io ~cl pa.ths, lhis technique:: places a response null on any non..:k:sired $0UI'tt. 

·rhus. this technique is applicable in Rr clutter cnvironmcnl$ using a Mulliplu Input - Mufliplc 

Output (MIMO) receiver. An e.xample or work in this area am be found in "'On the l'crfocmancc 

of 1be MIMO Zero.Fcw"Cing Receivtt in the 1-'resence or Channel Hstimation Error'' 116], which 

discusses the pc:rfonnance of a MIMO Zero Forcin,s: rc:ceiver with impcrfoc.t channel k.nowk:dge. 

While MIMO techniques consider multiple paths through a cluttered environment, MultiUser 

MIMO (MU·MIMO) supports multiplo users simul1anoously, 1'hus MU·MJMO roooiver.i are able 

to separote the signals frQm concurrent transmissions on tbc same rrec1ucney from different U$CI"S, 

1'his is achieved by using Lhe degroc:s or freedom provided by the multiple antenna and path$ to 

3cpuutcly i$01(11¢ C4CJ, indlviduaJ 3igflt~J. 01.e t'CICl'tll\t Mpe<:C of MIMO and C..'lp<:Cilllly MU· 

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MlMO is lbe suppression of other (non SO) signals. Although, there is a paucity Q( Utctatu:rc of 

SG MU·MIMO rejection of other widcband sig.n.'\ls, there is a &real deal 01'1 the ability to pick out 

a de.o;ircd (or many desired) signals from a mix of other sig..naJs. An ~ample of ellis taJlCtbility is 

discussed in .. LOS Tbroughpul Measuremen's in Rea!-Time with a JZS../\rwenna Massive MIMO 

Teslbcd,'" 1171. which provides performance rcsuluc rrom a testbed designed to experiment wilh 

various as-peelS or Massive MlMO. Another >er. "AirSyoo: f:.n:tl>ting Distribulod Multiuser 

MIMO With full Spatial MuJliph::xing,'" fi8J contains a study of a dislribute<l Mulli·User MIMO 

sysltJn using sp3tial multiplex and Zero Forcing that reports signnl rejection ot2S dB. 

3.3.2.2 Null Steering 

Null steering is modifying the antenna p:ntem to produce a nuJI in the dire<:tioa of an interference 

source. As sucll, h imp&ies o far field, phme wave model and is thcn~fore commonly ~ated 

with pl..-.sed ruroys. When in an uncluttered RF environment, null sleeting works well. An 

example of work in this area can be round in "Optimization of Array Pauc.m ror l!.ffi<:ient ContrOl 

or Adapth·e Nulling and Side Lobe Level." 114) which discusses 3t1 optimization tec;hniqoo 

applied to an'3)' synt))CSI,s whh lbc constrnint of reducing side lobe le\•cls. 

Null steering can achieve very deep rejections in rn~y cases. •soflNuJI: Many-Antenna full· 

Ouplcx Wircless via Di&i•at Oeatrd'ormh~s: I tSJ ail.:ll.yses lhe performance of a transmit null 

stetrin& algorithm to reduce seff~in~errcrencc for 11ntcnna structure.'\ supporting full-duplex 

opcnuioo, and reports reductions ranging from about 20 to 80 dH (see .,igures 8·9 of [ISJ). 

3.3.2.3 Antenna Side Lobe Control 

The an:.lysis provided in this ~per assumes either st:lndard tenec:cM fOt 1he ES and arrays with 

uniform :.lmplitll(le Utpcr f()f' tbe BS amcnoa. These types of :.tntennas.. h;,tve" fairly high level or 

side lobe$ starling at -13.3 dU frQm the main beam. 'rherc exists a large numbcl of ttd1niquoes to 

funher rodutedlesideJobelevel,each. with it.s own(:haf'3Cteriscics~ but industry sc:tndatd tcn ~ 

can readily achieve S-ide lobe levds well below ·20 d6. Soc "Side Lobe Level Roduecion In 

Antenna Army Using Weighting Function,'' (131 whioh includes an analysis. or various side lobe 

reduction techniques including a variety of commonly applied windows. 

4 DISCUSSION OF RESULTS 

·nao foregoing aMI)'$is or a typical deployment sc::c.nario shows that small FilCcd Service Satellite 

(FSS) Earth Stations (ES) with uplink trnns.missions between '17.2-50.2 and 50.4-S2.4 GHz. 

CQmmunicating with ge<>stntionary-orbit spaccc:r-..1'1, can be kJcated in the same urOOn areas as 

t-irth.Qenennion (SG} wireless Oase Stations (BS) wlthootthc .,ced rorcoordination.' 

The pritrt.ary coexistence metric U1ili7.ed is the ratio or f:SS ES received power dcm~ity (/,..) tQ 

ooise Ooor IX>wcr densily (fl.J at lhe 5V OS dcmodulat()r input, or 1,/f)..,. Ttl is metric is usod to 

determine the~. 98% nnd 95% probability contours for IJrt .. !!> -6 dB. 

11M: baseline confidence probability ro•nour data bas boe.n evaJooted with respect to a.bsolute area 

aod also area relative co a specific oo.nuy (i.e .. Cook County. IL). The results indi~te that for a 

2 Note; A• I)Olcd (*dicf-, lht t"Mdt~ o r d1i$ snalpa eXpend on d~e ch:uwlcmcia of the utclbtc lyltcm tt Wuc; 

the U'lcthodol<>&J retdUy could be •()lliX:d 10 f)"tttn. wid•~>thu lll.tCb.irtetiAt\'ll O.IJ~I (:Ot'lftg\tNIJOn'-

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gh·en £$,the an::a where a potential oot..\isu~ .• )C(: .ss~.~c coold CJ;ist is small, and •he chances of 

such 3 circumswnccaQuallyari.sing: in the real world is rnrc. 

As reported in Secrion 32.2, the lOCal 99% COflndcnce probability contour arta is le.~sthan 0.0036 

km• and 98111 oonto.ur Jess than ~2 km1, which oonsritute less tban 0.(l()(l()9'% Md 0.00001~ 

or Cook County. «.s~ive y. In ord<:r to aS$C$5 how unlikely It is that a 50 BS will experience 

an I.Jl'Jw g.reatc.r than ·6 dB, we will 111'$1 utilir.e Figure 18, which is a magnified view of the 

reglon of interest (rum l·igure 1:3. 

We at!SIO have "lumed around'" the pe.tS ~ive to focus on confidence 1hal lhe /,JTf.., will be 

srl!mu thtlll (>)the -6 dU gool. So, if at a given dis~MCC tht ooofidenet of lttf'f'J., being s -6 dO 

is X%, then thecorrcspoodingconridcncc.lh:l:t it will be> -.6d0 is (I~- X%). Thu.'i the~. 

98% and 95~J; regions b<:come the I%, 2.~ and ~ regions:. respectively. Recall from Figure II 

thnt the 9S pcroontile curve never fall.s bc.low the 11654 dB tJu'C.shold, so IJ'I" is less dmn ·6 dB 

at oJI dislances. and. we can therefore use the 5% J>CI'(CI\Iilc IJI'J .. > -6 d6 as a oooservative 

ceiling "*luc. 

Thcrerore. the two regions o( intcrcs.t can be defined a::c follows:: 

• 1,~ IT}.,.> -6 d.f) @between 2% & S% Rcg.jon (Uioo Shaded) 

o Area or1hc blue.sh.'ldcd teelangle 

o Size i$ ~20 m' 

• 1,. 111 .. >-<idB @ betwc:cn ltll & 2% Region (Rod Shaded) 

o Area or 1be rOO shOOed rectangle minus area of the blue shaded rectangle 

o Si1.e is - 3l60 m'l 

We can now make the conscrvath•e assumption that any 5(i B.~ deployed in the nxl shaded n::gion 

will have a pmbability or 1./Tt., > -6 dl3 o(24; and in the blue shaded region or S%. 'rllU.'>, using 

the total regicm ~ (3 160 m1 + 420 m'l = 3580 m2

) co weig.ht these prolxtbilities b:L.~ on the 

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ifkiividual region areas, the resulting probability ol' /,J11 .. > ·6 dB wuming a uniform likelihood 

of SO HS placement is approximately 0.024. 

We can now make tbc (also oonsc:rY~ltive) assumptlon that the FSS 1-:S is dtployOO in M ruea 

where 5G BSs are deployc.'d at the stllndard den$.ity (specined in 'ruble 12 or (7]) of 30 per km2

, 

Thus, the c:.'(pcctod number or llSs falling within the (;:()(lfldcncc regions unde1' di84'USSion i$ 

approximaltly 0.1. That is, the chaoce or a BS being in 1he confidence rogi()ns tmder discult:tion i§ 

roug.bly I in 10. 

This 8$5omption is conservative bteaust U1erc wUI be large areas of, for example. Cook County 

in wJ1ich no SG GSs will be deployed. Moody's Investor Servtce recently published information 

claiming t.hu.l SO system deployment will likely cover only 50% or lhc United St.QteS population 

1191. 

However, even if a SG BS happens to be dt-'J)IO)'ed in the discussed confidence regions (0.1 

l'robabilicy), lhe probabilhy that tho US actually will experien(C an /,/q.,. > 6 dB is 0.024. 

ThetefOft, the tolal probability that n 5G U.S will actu:tJiy experience -Jfl~~o > ·6 dB ui'Kk:r the 

temlsoftbis aoa.Jysis- is only0.0024,orapproximatdy 1 chanocein416. 

Notably, these re.~lts nre basOO on wnsen·ative as.~umptlons. including path loss. use of peak 

side lobes (inSlead ol acnl!LI lowet' values 3t djffereot off-axis angles). considering onJy BS 

antennas with essentially omni·dircctional QQvcrage. calculating much·Ngber confidence levels 

for received power density levels than oommonly U$Cd, ncx ac:courUh'l& roc auenuation from 

btoeka.ge, assuming sJI-outdoor SG deployment, and never considering the operation or nn US at 

M elevation Mgle above a minimal value. 

Mo~ovcr, the foregoing CB!culntloos do not take into a()(."(M)nt Ute mitigating effects of other 

raclOJ'$, such as FSS ES pl'lysical isoltltion and inhen:nt SG BS antenna amty technique.<>, which 

vittu:tlly eliminate the cha;lCC Q(a rcal-wortd problem ever actually arising. 

·1'1\us. tbe resuH.s of tbls analysis show that coexistence bd:woen FSS F.Ss and 5G BSs (using the 

dep!Qymenl scenario described in this p.1per) is feasible without the 1te«< (OC' (X)()(dination. 

5 REFERENCES 

[IJ .. Sharing and ColnJXItibilhy Sl\ldies or FSS and IMT Operating in the 37-50.2 (;Hi. 

Frequency Range."I)Qctuncnt No. USTGs.I..,OI, 'l'askGrouJ' 5.11.21 August 2017. 

[2) Recommcndi1Lion fi'U·R M.J8Sl. 06/2.009 .. Matbetnatical models fQr mdiodclcnnina4.ion 

mdar sy:«CJnil antenna pouems for usc in inccl'fereoce analyses-. 

(31 ECC PT I 154 Cas<:a.ls, Por1u~J . L6-20 Janu:u)' 2017 i.ssut:d I I January .. Sharing ana.l)'Sis on 

IMT-20201.tnd lntcr .... 'i.atellitc Servioe at 26 GUz. 

)41 AntcnM pcl'l'ormance standards, FCC 47 CFR 25.209. 

rs1 Recommendation rfU.T M.210 1·0.612017 .. Modeflingandsimulation or IMT ncCwOfksnnd 

systems for usc in sharing and oompatibility $1udies." 

rGI Nikolova 20 16, l.ecture 13: ••unear Array1'hcoty - p011. l." 

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Jto l811d As,.~att$,1.1.Ce 

17) "Uaison Statement IQ Task Group SJI: Spectrum Needs sod C.'bamc er stic.~ for the 

Tcm:.strial Component of IM'r in Lhe roctueney ~ange Between 2.4.'25 Gllz and 86 GH.~;.'' 

l>ocument .S-Ir.l6-E. Wortdng Part')' SO, 28 Fe.bnlal')' 2017. 

t8J "Autlcl'lmcm 2 on Spc:c1nun Needs to a Liaison Statement toTas.k GrQup 5/1: (.'hamctcristic.~ 

of Te.rrcsuial IMT S~ cm$ ror frtquency Sharing/ln tcff'eren~ Analyses in the FJ<:quei'ICY 

Range O.etwccn24.2S GHtand86GIIz," Worlclng Pnrty 50.28 February 2017. 

(91 Kim, Scungmo. et al.. .. Coexistence of 50 With the tncumbenlS in tho 23 and 70 OH7. 

Bands ... IEEH Jouma1 on Selected Arc3$ in Communications, Volume: :lS, Issue: 6. June 

2017. 

(IOl"Ot:l.Onel ul.odel for fNXJU<:.-.cy spectrum above 6 Gllz;· JGP'P 'I'R 38.900, Vcr:~ion 14.3.1, 

Release 14.July20J7. 

11 11 "Study on chnnncJ model for (rc<tucncy spccCtum above 6 GHz," El'SI TR l38 900. Vers:lon 

142.0, Release 14.Juoo 2017. 

1121 Rooonunendat:ion 11*U·R 1).526-13, Propagation by difrmction. P Series. Radiow:n'e 

propagation. November 2013. 

(131 Sartcr, ~oman , et. al., "Side Lobe Level Reductio•• in AotcrHla Army Using Wcishtin& 

Function,'' lntcmatiooal Confere.r1oo on Electrical Engineering and lnrormalion & 

Commonk:ntioo Tcchoology (ICEIII<.'l) 201~ . 

(141 Sarter. Roman, cc. al., "Optimi:r.aliM or Army Pauem ror Uffieient Control of Adaptive 

Nulling and Side Lobe Ltvel ,"The 201 S I EEB lmernational Conference on Common a~tion, 

Netwotks ~nd Satellite (COMNBTSAT). 

fiSJ Evereu. Evan, ct. aJ., •SoftNull: Many-Antenna F\111-0uple:< Wire!cs.s vi3 Dlg.itaJ 

B~mfonniug " IEEE Transactions on Wireless Communications. Volume: lS. J.ssue: 12. 

fleceJnbet2016. 

116} Wang, Cheng. Cl. at .. "On the Performance of the MIMO Zero-Forcing Rct"tiver in the 

J~oce of Channel f..stimntion &ror," IF.t:H ·rRANSACrlONS ON WJRHL£SS 

(."()MMUNICA1"10NS. VOL- 6. NO.3. MARCH 2007. 

LJ7) Harris. lltul. e.. 31., "LOS Throughput Meas-urements in Re11l-Time with a 12R-Anle.nna 

Mas-sive MIMOTestbed.'' GloOOI Communications Conferer1c:e (GJ.OJlECOM), 2016 ll-:F.f.. 

( 18) 8:1lan, Hori:-l, ct. al., .. AirSync: bn:lbling OistributOO Multiuser MlMO With Full S~tial 

Multiplexing."' rEEEIACJI.f Transactions on Netwol'l\ing, Volume: 21,lssue: 6. Doocmbcr 

2013. 

f J9) Moody's lnvcstemnt Se.rvioe. '"TelCO$ willltlilor Lhcir S(i strdtegies 10 miitch their individual 

strengths," https//www .m<)()dys.com. SeptembeJ-'2017. 

23 
93 

Roof and Ground Mount Satellite Earth Station-5G Sharing Analysis for 1.8 

m Satellite Earth Stations. 

Filed with FCC October 18, 2017, GN Docket No. 14–177. 


1025DANK83.eps
94 


1025DANK84.eps

-·- Rerised0ctoborl8..1017 

2-l Characterlsti<S of SG (JMT-2020) 

Tho SG system pammetetS 8tld deployment soonarios to be used in the sharing and oompatibility 

$1udles are found in the rru docume.n that is being used internationally to analyt.e frequency 

sbaringlinterference between IMT systems (i.e .. 50) and FSS networks in frequency bands 2A.2S 

GHtlo86GHz[3). 

Tho 5G systems secup is outlinnd in section 8 of Recommendation ITU-R M.2JOJ. In this analysis, 

the following SO parameten. aod configu.mtio.,s, and other salient methodologies, are used: 

l. One million snapshots are used tO generate the CDFs: 

2. e.i.r.p.densitiesarc -35.6dBm/Hz fO< OS and -50.9dBm/Hz for UE; 

3. Micro urban hotspot below the rooflincseenariowith BS heightat6 m and UEatl.S m. 

All BS and UE are <>uldonr. One square kilometer area includes •i• OS and three active 

UE per BS. The BS and UE are placed i11$ide thai area; 

4. The location orBS and UE vary for each snapabol. The Ul! are distribured in the area 

defined by theBS azimulh oovemgeof 120"degrees 8tld uplo tOO m from the OS. The 

BS azimulh coverage direecion is random for every soapahol; 

5. 20% nelwork loading aetivily facror reduces lhe 10tal number of &Clive BS and UE by 

80'0>; 

6. There are 30 OS per km' 8tld chroe liE 1ha1 can be assoeiatnd with each BS; 

7. TOO faecon reduces cbesimui1Al1eous cmnsmiiiSions of BS by 20% and the UE by 80\1',; 

8. AI each snapshot, the following pammeten are mndomized: 

locations of BS and the UE .. soeiated with thac BS; 

U. BS and UBantenna elevation and azimuth angles within a given sector 

depending on the link using beamforming antennas accordlr\g to 

Recommendacion ITU-R M.2101; 

iii. The BS and UE thai are active (based on TOO factor); 

iv. The UE trnnsmlt power control level based on the UE proximity to the BS; 

9. 8S do not use pOWOT control in the downlink; 

10. Reference emission bandwidth is 60 Mllz for BS and UE; 

II. The propogation model for the SG sySiem Is from Doe. 5-11.36. Micro urban se<:nario is 

used with panune1ers from Recommendation ITU-R P.l411 "Propagation data and 

prediction methods for lhe planning of short·range outdoor mdiocommunication 

systems and radio local area netw<Xb in me frequency range 

300MHz to 100 GHz". The paramelers for the non-line of sighl path loos with the 

coefficients (from P.J41 I Table 4) where =S.06,1\=-4.68, y4.02 and c-9.33. 

The t'C$uJts are presented as COJ;s for: 

I. .6S antenna gaJn toward We Ue; 

2. Downlink carrier·to-noisc C/N ratio. 
95 


1025DANK85.eps

l.Z Cbaratttrlstlcs or FSS systems 

· l -

Rcvlw:l OctQ'oor 18.l017 

FI(1UREJ 

BS to UEaatttlftaaain COP 

FIOURil2 

IS clown llrtk CIN 

The FSS characteristics used in this analysis art.s.hown in Table I below. 

TABLF.l 

fSS/8SS downlink paramd<d 

1.81h Oilmder 

&ut1a S~alion AnleM'* cllamet« m 

hak. rccdvo MICil.Ra ln db I 

Roc .. rru.R465-6 

1$0 

lotM'eteOOClONoitcR..tloi/N dB 
96 


1025DANK86.eps

··- 2.1 Analysis sotoarlos and assumptions 

The SO sewp is u described above. The SG stations an<! the fSS earth station are randomly placed 

at each snapshot as shown around a center point in the analysis area, which is one km1

• The 

snapsbot in Figure 3 is taken from one o( one mlllion iteradons. Note in Figure 3 tbe earth station 

icon is immersed inside the SG distribution and surrounded by the ioons for the various BS and UE 

stations. 

In each iteration of the simulation, the orientation of the earth station and the SG BS and UB 

slations will change. ln some cases, the orientation of UBand BB stations will result in alignment 

with the main beam of the earth station and the 8S antenna. In othetS, there wm be an alignment 

with the UB beam, and so on. The Visualyse software's Monte Curio process c:aleulates and ..ootds 

the 1/N into the ES rocoiver that results from that random plaoement of all the stations for that 

ltemtion. 

FIGUREl 

Bumple mapPot of 011e million ot th• nwdom pa.t'tmtnts or .SO 8S •M UE and tbe fSS atation 

Tho following assumptioM are also used-: 

I. The SG networir scenario ;, u described above; 

2. Cluner models used for the tmosmitlink from SG towards the FSS roce<ver are from 

DocumcntlTU·R TG S·l/38. Two models are used. The firnt is Reoommendalion rru- R P.200 I "A general purpose widc·mnge ter=trial propagation model in the fn:quency 
97 


1025DANK87.eps

· $ -

Rcvi:ted Oaob« 18.2:017 

mnge 30 MHz to 50 GHz'', The time percentages from 0 'l!> to 100% are chosen 

randomly fofeach time sample. The ocher is Recommendation ITU·R P2108 

;'Prediction of Clutter l..os$" section 32. The dutter is applied at the 5C transmitter side 

as well as lheFSS reeei\'ersideaccording to Recommendation ITU·R P.2108. The 

pen:cnt or loeatlons for cluuer is random hetween O'l!> and 100% for ···ery srunple'; 

3. The FSS center frequency Is 39 GHt; 

4. FSS antenna height Is 12 mecers or ground mouoted; 

S. For each BS,III..., UEareemployedatcenterfroquencies o£38.933 Gl{z, 39.0GHz 

and 39.067 GHt; 

6. Frequency dependent rejec(ion (FOR) is accounted for; 

7. Polari7Ation loss is set to3 dB; 

8. The FSS coexi>1Cocecriteria is under discussion willl.in the fi'U·R working parties. For 

Ibis analysis ·12.2 dB, ·IOdB and ·6dB are considered. The per<:entoftime 

exceedance is needed to detennine compatibility; 

9. FSS bendwidllls are SO MHz and 500 MHz: 

10. ~SO emission mask in dBc and 60 MHz. measurement bandwjdth are shown beJowj 

I I . Tbef'SS tueiverselec:tivity aresbown be1ow. The $t:lectlvity filters have -80dB per 

doeede slope from llle ·3 dB peint tO ·70d8 floor. A 18sterfilter roll.affcan provide 

bet.ter rejection~ 

12. 11te 12-meter-hlgh roof mount FSS ES installation is used, with a roofline, parapet wall 

or oilier shleldiog providing an additional R.F. isolation of at least20 dB to tbe SG BS 

and UB oonflgutatioo. 

13. The ground moont FSS BS installation plaoes lhe antenna mount at 2m above ground 

and uses an enclosure similar to Figure 7 that provides an additionnJ R.F. isolation of at 

least 20 dB to the SG BS and UE stations. 

... 

... !..o.c 

. 

~)0.0 

~NO 

w• 

•• ... 

FIGURB4 

Oattcr loss 

I Note tht$t clutter modcls do not account for clu1ter closer than 2SO m from the station. 
98 


1025DANK88.eps

FIGURES 

5Gmlsslonm..U 

• ......... u.~.,., .... ......_ ............ 

. ~ - I I 

I 

~ I 

, I I 

I I r L _______ _j L. ___ ,_j 
99 


1025DANK89.eps

Figure 7 

Full! Hnelnsed Ground Mount 
100 


1025DANK90.eps

·•-

3 RESV~TS 

The re$Uitsoftbesimulations for the three liN values are shown below. 

TABI.£2 

!G and roor mouottd 1.8 m f'SS £S SUIIIIIIAI'1 ot~ull'l 

50 300 

99.69 99.99 

99.81 99.99 99.98 100 

Table 2lndicates dlat with a greater than 99.69% oonfidenoe level (roughly 3 sigma) that a roof 

mounted earth :station of the type considered here, and with the minimum additional20 d.B of 

attenuation reasonably e;~~pectcd of a roof top installation. could be deployed within a SG network 

and 001experlenoe more than ·12.2 dB UN. 

The CDF plot in Figure 8 below sbows the perocn13ge of simulation iterations where the 1/N wos greater than a given value. The pi()( shows that for the vast majority of random deployments of 

stations, the expected level or liN was vanishingly small. 

TABLE3 

SG and IN)UI\dmounttd I.Sm FSS ESsummU)'orruult4 

50 300 

98.7~ 99J96 99.134 99.S90 

99.614 99.81'2 

Table 3 indicates that with a greater than 99.4% oonfidcnoo level (nearly 3 sigma) that a ground 

mounted earth station of the type considered here, operating with a 500 MHz wide crurier (such as 

that used by Vla..<;at), and with the mjnimum additiooal20 dB of auenuatiOJl reasonably expected of 

a bloelc wall enclosure, could be deployed within a 50 networlt and nO( CJ<porience more than ·12.2 

dB UN. Based on ViaSat's previous testing.'il is actually more reasonable tO expect 25 dB t030d8 

of attenuation from such a block wall enclosure. Factori.ng in such higher signal attcmJ:Btion, for 

example, the 98.7.16% value becomes 99.5% widl25 dB of such attenuation, and it hecomes 

99.784% with 30 dB of such attenuation. 

The CDF plot in Figure 9 below shows the peteentage of simulation iterations where lhe 1/N was 

greater than a given value. The plot shows that for the vasr majority of random deploymenu of 

staliOJ'ls, theexpectod le .. ·d of 1/N is vanishingly small. 

• See reference (4). 
101 


1025DANK91.eps

_,_ 

R••lmOccobot 18,2017 

fiGURES 

SC System a.ad 1.8 m Dlam.eltr fSS &S at htl&bt of Ilea COfJ 

figl.)ft9 

~Syste. and I.S•DiuM:m-Croud Mounttd Jo'SS IS CO'• 

•. 

L 

1.. ! 

. . 

... ... ...... 
102 


1025DANK92.eps

.(0-

R.c..ued ~obcr 18.1017 

4 CONCLUSlOl< 

The analysis above shows that when a roof mounted or ground mounted 1.8 m diameter FSS is 

pl$(,.-ed i1tslde a SO distribution in an urban clutter zone, and the roof line, a parapet wall, block wall 

enclosure, or other shielding provides at least an additiona120 d.B or attenuation over normally 

~peered cJutter losses, the potential impact on the FSS rocciver is negligible and ooordtnation of 

stations is not required. 

This result is oonsistent with measurements taken of a roof mount transmit earth s.tatJon at 28 GH~ 

which demonstrated the positive impact of locating the earth slalio•l in such a typical roof mount 

oonfigumtion {4], where in most cases tbc attcnuatiou was greater than 20 d.B. and more than 40 dB 

or beyond lhc measurement capability of the test equipment in many cases, and with the Roberson 

report which con<idered the uplink (Earth-to-spooe) scenario in an urban setting and that also 

oonchtded that ooexistcooe is feasible without (:()()('dination because tho transmit earth scation can 

operate ln close proximity to tlte 50 network. 

5 R!l>ORtNCSS 

(I) Roberson Report,attacbed to ViaSat,lnc. Ex Parte Submission in ON Docket No. 14-177, 

September 25 2017 

{2) ffU WP5D Uaison to TG 5/1 

[3] Doc. ITU-R TG i:ill.§, Attachment 2 

[4) carlsbad Report, attached to VlaSat,lne. Ex ~'lim Subn\lsslon In ON Oodcet No. 14-177, April 

20,2017 

October 18,2017 

ChiefTecl!nology Officer. Regula!Of)l AITalrs 

ViaSat, Inc. 

6155 El <:am! no Real 

Cansbad,CA 92009 
103 

The CHAIRMAN. Thank you, Mr. Dankberg. 

And before I turn to Mr. Spengler, I’ll just say we’re going to 

have a vote at 10:30. We try to rotate Members so that we have 

people here to cover it, and we’ll just keep right on rolling. But 

thank you. 

Mr. Spengler. 

STATEMENT OF STEPHEN SPENGLER, 

CHIEF EXECUTIVE OFFICER, INTELSAT 

Mr. SPENGLER. Thank you, Chairman Thune, Ranking Member 

Nelson, and members of the Committee. 

I’m proud to lead Intelsat, the world’s leading provider of satellite services. We have a fleet of 50 satellites, a sophisticated terrestrial infrastructure. We operate the first truly global network for 

video broadband that covers 99 percent of the world’s populated regions. 

Our ultimate goal is a world with ubiquitous connectivity and no 

communications boundaries. To make that a reality, we have invested billions in high-speed satellite technology. We’ve been pioneering satellite communications since 1965 when we launched the 

first commercial communications satellite, Early Bird, at the dawn 

of the Space Age. Four years later, we transmitted the pictures of 

Neil Armstrong’s first step on the Moon to the world. Today, 50 

years later, we’re a public company listed on the New York Stock 

Exchange with over $2 billion in annual revenues, and we employ 

1,000 people here in the U.S., with the majority based in Clean, 

Virginia. 

We’re committed to taking the next giant leap forward for satellite technology in the 21st century, whether that’s launching 

next-generation satellites or preparing for innovative smaller, lighter ground antennae. 

While Intelsat is largely a business-to-business company, our 

customers are in media, maritime, aviation, telecom and enterprise 

networking, the U.S. military, and emergency services. They rely 

on Intelsat to provide broadband video, secure satellite communications, and mobility services. In media, we distribute video programming for most of the U.S. broadcasters and programmers, including 

CBS, NBC, Disney, ABC, Fox, Discovery Channel, Turner, and 

HBO. In the air, we’re a major supplier of WiFi broadband 

connectivity for airlines such as United, Southwest, and Delta; and 

on the oceans, to major cruise ship companies. 

In rural America, satellite bridges the last mile, where cell towers and fiber don’t reach. In Alaska, for example, we help provide 

connections to enable telemedicine for residents and distance education for K–12 students. And in the U.S. military, we’re proud to 

bring the Nation’s soldiers, sailors, airmen, and Marines the critical communications capabilities they need to carry out successful 

missions around the globe. 

Satellite solutions are uniquely sustainable during natural disasters. When fiber is cut, cell towers washed away, the electricity is 

out, and other means of communications are down, satellites remain in place in outer space. We provided disaster recovery and 

emergency services to locations such as Puerto Rico and the U.S. 

Virgin Islands after the recent devastating hurricanes. We anVerDate Nov 24 2008 13:09 Mar 27, 2019 Jkt 000000 PO 00000 Frm 00107 Fmt 6633 Sfmt 6601 S:\GPO\DOCS\35753.TXT JACKIE
104 

nounced this week that in Puerto Rico, Intelsat is working with 

U.S. antenna manufacturer Yenta and telecom operator Liberty to 

deliver necessities and Internet connectivity to residents. 

This is an exciting time for the satellite industry. Given the insatiable demand for affordable connectivity everywhere and at all 

times, satellite is converging with other telecommunications technologies to build one common telecommunications infrastructure. 

Intelsat designed and now has in service a high-performance, nextgeneration satellite platform, Intelsat Epic. Intelsat Epic offers 

greater efficiency in the use of spectrum and more powerful and affordable services for customers. 

We all know about the connected car. Intelsat is leading the way 

with a satellite solution for the future where software will be as 

important to our transportation as the latest design features. Satellites will work seamlessly with terrestrial networks in the connected car environment. Some applications will run over the wireless network, but cars will get their software updates over satellite. 

The broadcastability of satellite from point-to-multipoint is highly 

efficient. Car companies can update thousands of cars at once, and 

these connections are more secure. 

Satellite networks can operate fully separate from the public network, dramatically reducing the cyber threat entry points, making 

automated cars safer for all citizens. 

Intelsat has also invested in and partnered with OneWeb to utilize the power of a combined multiple constellation solution that 

will enhance the worldwide connectivity for mobility, wireless extensions, and military services. 

Finally, in response to a recent FCC proceeding, Intelsat is leading with a creative market-based approach in proposal that will 

pave the way for joint use of C-band radio spectrum in the United 

States without risking significant reliability issues in interference 

for American television viewers. This spectrum is highly prized for 

both satellite television distribution and 5G wireless services to 

millions of American homes and consumers, and we’ve proposed a 

solution that allows for both sectors to flourish. 

At a time when access to secure and reliable communications impacts everything from the economy to national security, Intelsat is 

playing a major role innovating for our Nation’s infrastructure. 

Thank you. 

[The prepared statement of Mr. Spengler follows:] 

PREPARED STATEMENT OF STEPHEN SPENGLER, CHIEF EXECUTIVE OFFICER, INTELSAT

Chairman Thune, Ranking Member Nelson and members of the Committee, thank 

you for the opportunity to appear before you today. I am Stephen Spengler, Chief 

Executive Officer of Intelsat and I’m pleased to have this opportunity to speak on 

behalf of our company, our customers and the many communities around the world 

that we serve via satellite. 

Our Company 

Intelsat is the world’s leading provider of satellite services. With a fleet of 50 

high-speed satellites, and a sophisticated terrestrial infrastructure, we operate the 

first truly globalized network for video and broadband that covers 99 percent of the 

world’s populated regions. Our goal is a world with ubiquitous connectivity and no 

communication boundaries. We have invested more than $2 billion in high-speed 

satellite technology to make more efficient use of spectrum, which enables more affordable broadband connections for businesses, machines and people. 

105 

Intelsat has the capability to serve citizens and organizations everywhere, from 

remote, rural regions in the U.S. to the world’s mega cities and to emerging regions 

that have been able to advance education, health services and economic prosperity 

through increased connectivity. 

I have seen first-hand how broadband connectivity and information communications technology can transform and empower communities. Our investments in innovation and new services such as hybrid terrestrial and satellite networks have 

helped to make this possible. Digital connectivity and inclusiveness is critical to our 

ability to grow our economy here in the U.S. Satellites play an instrumental role 

in the infrastructure that enables this connectivity. 

We pioneered the satellite communications industry. Intelsat was originally conceived as a multi-country treaty organization at the dawn of the space age. We designed and launched the first commercial communications satellite, Early Bird, in 

1965 and ‘‘live via satellite’’ was born. We broadcast the first live international satellite TV production in 1967, which featured the Beatles’ first performance of All 

You Need Is Love. We transmitted the pictures of Neil Armstrong’s first small steps 

on the moon. Today, 50 years later, we remain committed to taking the next giant 

leap for satellite technology—whether that’s launching our high-throughput Intelsat 

Epic NG next generation satellites, preparing for a new era in lower earth orbit satellite constellations or investing in the next generation of smaller, lighter ground 

antennae that you will soon see appearing on planes, ships and other vehicles. 

Intelsat today is a public company listed on the New York Stock Exchange 

(NYSE: I). We have annual revenue of more than $2 billion, committed future orders of $8 billion, and we employ 1,000 employees in the U.S., the majority of whom 

are based in McLean, VA. 

What We Are Doing Today 

We are largely a business-to-business company, but Intelsat services enable many 

aspects of the daily lives of your constituents. Our customers in media, maritime, 

aviation, enterprise networks, the U.S. military, and emergency services rely on 

Intelsat to provide broadband, video, secure satellite communications and mobility 

services. 

In media, we distribute video programming for all of the major U.S. broadcasters 

and programmers including Disney, Fox, Discovery Channel, Turner, HBO and 

CBS. Hundreds of millions of U.S. citizens experience our services when they watch 

an HBO movie, the Olympics or the Super Bowl. The cable industry delivers 1,500 

channels to 61 million subscribers through 5,000 ‘‘headends,’’ or key points of distribution for cable providers. As a satellite provider, we can deliver HD channels 

to those 5,000 sites at 99.999 reliability, which ultimately costs the consumer only 

pennies. No other technology can deliver these economics. 

In aviation, WIFI inflight is so important to airline passengers that it’s become 

more essential than extra legroom. Intelsat has invested in its global fleet to support the global aero and mobility markets. We are a major supplier of broadband 

connectivity to airlines such as United, Southwest and Delta through infrastructure 

providers. We have made great strides to support these providers as they develop 

new services for domestic as well as international air routes. Intelsat also provides 

aeronautical broadband connections for senior government leadership. 

At sea, demand for bandwidth has grown exponentially. Just a few years ago, a 

cruise-going family might have brought a single laptop and a cell phone aboard ship. 

Today, cruise companies find that the average family boards a ship with 10 connected devices. And they expect the same performance at sea that they have at 

home in the U.S. The demand for connectivity aboard a ship is a solution that only 

satellite can satisfy and Intelsat serves major cruise lines. 

Intelsat provides critical network connectivity for many businesses overseas and 

even here in the U.S., complementing terrestrial networks. Our corporate data network helps the oil and gas industry to operate efficiently in remote geographies and 

ocean environments. They require satellite services to connect to their rigs, providing not only operational connectivity, but also broadband services that allow the 

crews to communicate with family members while on location. Whether it is transmitting data from seismic exploration ships, supporting mission-critical drilling operations or employee communications, satellite services are critical to the production 

of oil and energy in the U.S. and beyond. Retailers use satellite to create customized 

broadcast networks to educate their employees and for transaction-based services, 

such as pharmacy and credit card applications. 

In rural communities across America, satellite bridges the last mile where cell 

towers and fiber don’t reach. For example, in rural Alaska, through a partner, we 

provide connections to enable telemedicine for residents, distance education for K– 

106 

12 classrooms and virtual field trips for students to places like the Baseball Hall 

of Fame, zoos and aquariums located in the lower 48. 

We are also very proud to partner with the U.S. military to bring the Nation’s 

soldiers, sailors, airmen and marines the critical communications capabilities they 

need to successfully carry out their mission around the globe and here at home, both 

in the sky and on the ground. Whether it’s manned or unmanned aerial vehicles, 

communications on the move, or social and recreational welfare, Intelsat satellites 

carry the signal for our military and our troops. 

Satellite solutions, which offer sustainable connectivity, are unique in their ability 

to provide near-instant communications networks in areas where disasters have 

crippled terrestrial infrastructure. When fiber is cut, cell towers washed away, the 

electricity is out, and other means of communication are down, satellites remain in 

place in outer space. We provided disaster recovery and emergency services to locations such as Puerto Rico and the U.S. Virgin Islands after the devastating impact 

of Hurricanes Harvey, Irma and Maria. Intelsat provides the communications that 

are vital in enabling medical services and simply connecting people to loved ones 

concerned for their welfare. 

This week we announced that in Puerto Rico, Intelsat is working with U.S. antenna manufacturer Kymeta to deliver mobile communications to Liberty Global. 

Three vehicles, dubbed Liberty 1, 2 and 3 are travelling throughout Puerto Rico for 

the remainder of the year to deliver necessities and Internet connectivity to residents. Working with Kymeta’s roof-mounted, electronically steered flat panel antennas which are installed on the vehicles, this combination delivers high-speed, reliable Internet connectivity to residents, helping the islands and their residents return to normal, day-to-day activities. 

What’s On the Horizon 

The satellite industry is at an exciting inflection point. Given the insatiable demand for affordable connectivity, everywhere, and at all times, satellite is converging with other telecommunications technologies to build one common telecommunications infrastructure. The demand is ubiquitous and satellite is a part of 

the solution. To that end, Intelsat has been innovating in the design of our satellites 

and is advancing new antenna technologies. We understand that connectivity is critical to economic growth in the U.S. and around the world and we have invested in 

innovation that will ultimately improve the lives of citizens and move our society 

forward. 

Intelsat designed and now has in service a high-performance, next generation satellite platform—Intelsat Epic,NG which offers greater efficiency in the use of spectrum and more powerful and affordable services for customers. 

We have all read about the connected car and the autonomous car. Intelsat is 

leading the way with a satellite solution for the future, where software will be as 

important to our transportation as the latest design feature. For example, luxury 

cars currently are designed to include over 100 million lines of code—that’s about 

14 times more than even a Boeing 787 Dreamliner jet. Auto manufacturers are excited about the potential of being able to monitor vehicles and their systems remotely and provide simultaneous software updates to all the owners of a particular 

model using the point-to-multipoint broadcast feature of satellite. What a game 

changer to think that the car you buy today will get better and safer as new software features become available. The elimination of the need to bring cars into the 

dealership for simple code updates will save money and time for manufacturers and 

drivers. 

Satellite will work seamlessly with terrestrial networks in a connected car environment, with some applications—such as nearby traffic problems—running over 

the wireless network. Other applications, like software and mapping updates, will 

be assigned to satellite. Not only is the broadcast feature more efficient, reaching 

millions of drivers with one signal, it is also more secure. 

Whereas every wireless connection represents a cyber threat with respect to a network, satellite networks can operate fully separate from the public network, reducing the cyber entry points dramatically, making automated cars safer for all citizens. 

Intelsat has invested in our partner Kymeta which is inventing a new type of satellite antenna designed specifically for the connected car and other mobility applications. 

Intelsat has also invested in, and partnered with, OneWeb. OneWeb is a startup low-earth orbit (LEO) satellite company and you will hear from its founder and 

Executive Chairman, Greg Wyler next. Utilizing the power of a combined, multiorbit Lower Earth/Geostationary solution will also enhance the worldwide 

connectivity for mobility, wireless extension and military services. 

107 

Finally, we all know that with this ubiquitous connectivity demand comes a relentless demand for access to more spectrum. Spectrum is key to all communication 

services—satellite included. Intelsat has recently taken a leadership role on an initiative that could bring more reliable and faster broadband services to millions more 

Americans. In response to a recent FCC proceeding, we have proposed a marketbased solution that would pave the way for joint use of C-band radio spectrum. This 

spectrum is highly prized for both satellite television distribution and 5G wireless 

services. 

Sharing C-band spectrum under traditional circumstances can create significant 

reliability issues and interference, putting viewing audiences and other users at 

risk. U.S. media companies depend on C-band for program distribution, whose characteristics allow transmissions of pristine quality. But we recognize that 5G is the 

next generation of mobile technology and satellite will play an important role in extending 5G services rural and remote communities. 

Our creative proposal, developed with Intel, provides a framework for managed, 

joint-use of the C-band spectrum in the U.S. market that may enable wireless and 

other service providers to accelerate their deployment of 5G. Unless the joint-use of 

spectrum is managed in a way that respects the needs of all users, companies that 

have invested billions of dollars in infrastructure will be at risk. Whether they’re 

watching Monday Night Football or a Nickelodeon cartoon, American television 

viewers expect—and deserve—high quality images and 100 percent uptime. Our proposed plan offers a win for everyone. We believe it’s time for the satellite operators 

and others industry participants to embrace this opportunity to create more economic opportunity for themselves, American business and U.S. citizens. 

We are now in a productive dialogue with a number of stakeholders to turn this 

proposal into a reality. We are grateful to the FCC for its openness in considering 

market-based solutions that will result in the highest and best use of spectrum and 

accelerate innovation in this country. 

Conclusion 

We appreciate the Committee’s interest in learning more about our evolving industry and the impact the industry has on various customers. At a time where access to secure and reliable communications impacts everything from the economy to 

national security, Intelsat is pleased to be playing a major role in innovating our 

Nation’s infrastructure. Intelsat is dedicated to envisioning the future and enabling 

connectivity everywhere and anywhere on the planet. 

Senator WICKER [presiding]. Thank you very much, Mr. Spengler. 

Mr. Wyler. 

STATEMENT OF GREG WYLER, FOUNDER AND EXECUTIVE 

CHAIRMAN, WORLDVU SATELLITES LIMITED (ONEWEB) 

Mr. WYLER. Thank you, Senator Wicker, Ranking Member Nelson, and members of the Committee. Thank you for the opportunity 

to testify before the U.S. Senate about OneWeb’s mission to bridge 

the digital divide. We will spend billions to build the world’s first 

large-scale constellation and launch our fleet in the coming months. 

We will begin bridging the American digital divide in 2019 by enabling low-latency broadband coverage for every home, school, and 

hospital in Alaska. In 2020, we will reach every square mile of 

America. This means a brighter future for the nearly half of Americans with substandard Internet access, primarily in rural areas. 

This will be a foundation for ubiquitous 5G service, the Internet of 

Things, connected vehicles, telemedicine, and online education. 

Our initial system, with peak speeds of 500 megabits per second, 

is just the beginning. Our second constellation, planned for 2021, 

will enable ultra high speeds beyond 2.5 gigabits per second, faster 

than fiber, direct to every rural home using a small lightweight antenna. 

We have a third constellation planned for 2023, which will continue to increase our total capacity until we can support 1 billion 

consumers globally by 2025. In total, we look to invest nearly $30 

108 

billion to achieve our mission of fully bridging the global digital divide by 2027, and this will start right here in the United States. 

Today, total satellite capacity is a few terabits per second. 

OneWeb will have 7 terabits per second in its first constellation, 

over 120 terabits per second in its second, and has achievable plans 

to reach nearly 1,000 terabits per second, that’s one petabit per second, by 2025. Over the past few years, we have raised nearly $2 billion from 

caring shareholders with industry and distribution expertise, including Softbank, Qualcomm, Hughes, Intelsat, Coca-Cola, the Airbus Group, and the Virgin Group. 

To build this system, we needed to break new ground in satellite 

development. In March, we began construction of the world’s largest purpose-built satellite manufacturing facility in Exploration 

Park, Florida. This $85 million project will soon produce 15 satellites per week. This factory is creating 250 high-paying jobs— 

high-paying engineering jobs—with multiplier effects for the regional economy. 

With thousands of satellites to manufacture, hundreds of rockets 

to order and launch, and billions of people to connect to our system, 

this is not easy. But today, OneWeb satellites are under construction, the rockets are in place, and our first launch is in May. 

OneWeb was founded with the mission of enabling affordable access for everyone, and we must do so while protecting our precious 

space environment. I have spent the past 15 years on this mission. 

It’s a life’s mission and one deeply held by all of us. 

In 2003, I began connecting hundreds of schools and communities 

in Rwanda, building the first fiber to the home and the first 3G 

network in Africa. With each connection, I saw the impact on individuals and communities. I also saw the potential of small ISPs 

and telecom operators, which is why OneWeb will partner with, 

rather than displace, local operators and aspiring entrepreneurs. 

In 2007, I founded O3b networks, which has launched 12 satellites. O3b has the distinction of not only being the fastest and 

lowest latency satellite system to date, but also the only NGSO 

broadband system to not have gone bankrupt, which illustrates the 

challenges and fragility of this industry. 

This is hard, but we must overcome these challenges responsibly. 

Together we must lead in setting the global standards for protecting our fragile space environment because the consequences if 

we do not are dire: space debris, reentry casualties. These are serious risks which come from substandard components and a lack of 

an adequate regulatory environment. 

We know that a single impact between satellites can cause thousands of debris fragments. At OneWeb, we recognize the responsibility of being on the leading edge, and as the first to launch a 

large constellation, we have taken great care not to physically overlap our orbit altitude with prior filed systems to reduce the risk of 

inter-constellation debris creation. These best practices have been 

adopted by others, as there remain many altitudes for safe space 

operations. 

Ranking Member Nelson, Senator Wicker, and the members of 

the Committee, thank you for the opportunity to testify today. We 

know you understand the moral urgency of this mission. We know 

109 

you see the issues as you visit rural townships and populations 

where millions of Americans live without access. We are not here 

to ask you to get behind us with CAF or other government subsidies; we are here to stand by your side and bring connectivity, 

jobs, and economic prosperity by connecting people in rural America to their opportunities. 

[The prepared statement of Mr. Wyler follows:] 

PREPARED STATEMENT OF GREG WYLER, FOUNDER AND EXECUTIVE CHAIRMAN, WORLDVU SATELLITES LIMITED (ONEWEB) 

Chairman Thune, Ranking Member Nelson, and Members of the Committee, 

thank you for the opportunity to testify before the United States Senate about 

OneWeb’s mission to bridge the digital divide with our exciting new satellite technologies. This is a great time to discuss our progress as we are investing over $4 

billion to build the world’s first large scale satellite constellation, and will begin 

launching our fleet in the coming months. 

In 2019 we will begin bridging the American digital divide by making low latency 

broadband available for every citizen in Alaska. The next year, OneWeb’s broadband 

will reach every square mile of America and its territories, leaving no one behind. 

This means a brighter future for the half of America with substandard access to the 

internet, primarily in rural areas, and will be a foundation for ubiquitous 5G service, enabling the Internet of Things, connected vehicles, telemedicine and online 

education. Importantly, as a global system, we will connect American small businesses to the 50 percent of global markets that currently have limited or no access. 

Our initial system with peak speeds of 500mbps is just the beginning. Our second 

constellation, planned for 2021, will augment the first and increase this speed, up 

to 2.5gbps, for every rural home. Beyond this we have a third constellation planned 

for 2023 which will continue to increase our total capacity until we can reach 1 billion users globally by 2025. In total we will potentially invest nearly $30 billion to 

achieve our mission of fully bridging the global digital divide by 2027. 

OneWeb’s capacity is more in line with a terrestrial system than historical GEO 

satellites. For instance, the total GEO satellite capacity today is several terabits per 

second (tbps). In comparison, OneWeb will have seven tbps in its first constellation, 

over 120 tbps in its second, and approach one Petabit per second (1000 tbps) by 

2025. 

Importantly, access to our services will be simple. The services will be offered by 

local ISPs and telecom providers. The terminals will be small, inexpensive, and 

lightweight so they can be installed by anyone. They will be low power so they can 

operate from built-in batteries or a solar panel. This unique aspect of OneWeb’s system design will be a game-changer for those with intermittent power or those without power in emergency situations, rural areas and developing countries. 

With thousands of satellites to build, hundreds of rockets to order and launch, and 

billions of people to connect to our system, this is not easy. But we have made significant progress. OneWeb’s production satellites are under construction. The rockets are in place and our first launch is in May. 

OneWeb’s System Design and Accomplishments 

In the past few years, OneWeb has made remarkable progress towards achieving 

its mission. As the first filed and announced direct to consumer NGSO constellation, 

OneWeb has been a trailblazer in design and manufacturing, and has achieved 

many milestones: 

• Formed in 2012, years before any other applicant, OneWeb designed and filed 

for the first NGSO system capable of providing low cost consumer broadband; 

• OneWeb has raised nearly $2 billion in equity from shareholders with deep industry and distribution expertise, including Qualcomm, Hughes, Intelsat, CocaCola, Airbus Group, the Virgin Group, and the Softbank Group; 

• OneWeb is one of the world’s largest launch purchasers and has reserved and/ 

or manifested launch capacity from Blue Origin, Arianespace and Virgin Galactic; 

• As the first applicant at the FCC, we spearheaded the use of NGSO spectrum 

combined with a sustainable satellite design to reach rural populations, and received the first U.S. market access grant from the FCC in June 2017; and 

• OneWeb innovated the first low-cost, high performance NGSO satellites for 

mass production, leading to the creation of the world’s first and largest purposeVerDate Nov 24 2008 13:09 Mar 27, 2019 Jkt 000000 PO 00000 Frm 00113 Fmt 6633 Sfmt 6621 S:\GPO\DOCS\35753.TXT JACKIE
110 

built production satellite factory responsible for 250 new engineering jobs in Exploration Park, Florida. 

To build this system we needed to break new ground in satellite manufacturing. 

Earlier this year we did just that, and our $85 million specialized facility in Florida 

will soon start production. Capable of producing 15 satellites per week, this new factory has also had multiplier effects for the regional economy. For instance, this summer RUAG, a space components manufacturer, moved its facilities from Switzerland 

to Titusville, FL to be near our factory. Their foreign direct investment in America 

is creating 80 new jobs in an area which has been hit hard following the retirement 

of the Space Shuttle. 

Figure 1: OneWeb Satellites Factory under construction in Exploration Park, FL 

Our Mission 

OneWeb was founded with the mission to bridge the digital divide. 

I have spent the past 15 years focused on this mission, one that is deeply held 

by many if not all of you. After selling my first company which specialized in semiconductor cooling technologies, I traveled to Rwanda, Africa. It was then a country 

torn by history and without connectivity. In 2003, I began connecting hundreds of 

schools and rural communities to the internet, building the first fiber to the home 

and the first 3G network on the continent. 

Figure 2: Fiber installation in 2003 in Kigali, Rwanda 


1025WYLE1.eps 1025WYLE2.eps
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1https://www.washingtonpost.com/news/the-switch/wp/2017/09/28/this-is-how-bad-cellservice-in-puerto-rico-is-right-now/?utm_term=.d0502b304c7c 

With each connection, we saw the positive impact of community access on education, telemedicine and opportunity. I saw children who, for the first time, could 

explore their personal interests as deeply as they liked. With local teams, we pushed 

the boundaries to deploy the newest technologies in some of the hardest to reach 

and neediest rural populations in the world. It was there that I also saw the potential of small ISPs and telecom operators, which is why OneWeb will partner with, 

rather than displace, local operators and aspiring entrepreneurs, and much of our 

systems revenue will remain in the communities that it connects. 

In 2007, I founded O3b Networks, which stands for the ‘‘other three billion’’ and 

has launched 12 satellites. O3b has several distinctions. Not only is it the fastest 

and lowest latency satellite system to date, but it is also the only NGSO communications system to not have gone bankrupt. Today O3b, now fully owned by SES, is 

considered a success, but there is an important lesson here. This is a fledgling industry where failure is normal, and building these systems requires a deep and passionate commitment for something more than just financial returns. 

In 2012, I founded OneWeb, continuing the commitment to close the digital divide. 

Today, I am glad to see the Committee properly considering the leading role new 

satellite technologies can play in next generation broadband systems which will 

have higher performance, better reach and resiliency for emergencies. 

Recently, Hurricane Harvey disrupted terrestrial communications networks across 

the southeastern U.S. Hurricane Maria also brought catastrophic damage to Puerto 

Rico, making cellular service almost nonexistent after damaging nearly 90 percent 

of cell sites.1 In the aftermath of these natural disasters, satellite networks provide 

vital connectivity faster than any other option. And the faster communities reconnect, the faster recovery starts. OneWeb’s highly resilient network will provide another level of critical connectivity to first responders and victims when tragedy 

strikes. 

Challenges and Recommendations 

Bridging the Digital Divide must include sustainable development. This means 

bridging the divide without harming space for future generations. We cannot overlap constellations in a way that would risk creating space debris, or endanger humans on Earth by using less expensive materials which do not degrade on re-entry. 

OneWeb has been focused on sustainable space development since the beginning. 

We know that a single impact in space can cause thousands of debris fragments, 

fouling orbital altitude ranges for hundreds, if not thousands, of years. The Iridium/ 

Cosmos event is just one of several costly, environmentally damaging examples. To 

prevent collisions and a cascading of damaging events, large scale constellations 

must have a minimum altitude spacing (MAS) for safety. 

We were the first to design a large constellation and took great care not to overlap 

any prior filed system. For the sake of future generations, we cannot take the collision risk of overlapping constellations. There are many altitudes available for safe, 

separated operation, yet with tens of thousands of satellite filings in process, overlapping may happen as there are currently no meaningful regulations on this matter. 

The last significant U.S. regulation on space debris is more than 20 years old. The 

international treaty called the Outer Space Act was adopted in 1967. This has created a regulatory gap, and while many countries are drafting papers, this is a place 

where the United States can take a leadership position and drive standards of excellence and stewardship worldwide. NASA is conducting a study on large constellations due later this year, and at a minimum this can inform such standards. 

We have worked with the industry, including Boeing, to develop best practices for 

an appropriate MAS. A MAS of 125km can help isolate the impact of any single system which suffers a collision. While many satellites have onboard propulsion and 

accurate station-keeping, we also know that satellites fail, and when they do the potential for collision rises. In such a case, keeping safe distances between constellations protects against cascading events. 

OneWeb is also pioneering the use of grappling mechanisms for the removal of 

satellites. We will include these grappling mechanisms on all of our satellites for 

future space tugs, and we hope to open source these designs so every constellation 

may use a standard grappling interface to remove failed satellites. The development 

of satellite service technologies, like those at the West Virginia Robotic Technology 

Center, will play an important role in protecting altitudes from the many potential 

failed satellites. 

112 

OneWeb also pioneered new standards calling for de-orbit within five years. We 

carry enough onboard propulsion to safely and accurately de-orbit each satellite. We 

are glad to see others adopting this practice as well, as it is crucial to ensure satellites do not remain in the small and fragile LEO environment. 

Related to the five year de-orbit period, we have also ensured our satellites will 

disintegrate on re-entry. We do not use materials which will survive de-orbit. While 

more expensive and more challenging, it is the proper practice rather than facing 

the possibility of fragments on the ground, and possibly causing re-entry casualties. 

While there is an old rule requiring individual satellites to have less than a 1:10,000 

chance per year of causing a re-entry casualty, this rule needs to be updated to 

apply to large constellations that, unchecked, will drop tens of thousands of fragments. 

Space is an unforgiving environment. Satellites can fail, and re-entry is always 

a concern. Just last year China lost control of its Space Station Tiangong-1. Operating at 349km, its re-entry date is predicted between October 2017 and April 2018. 

While this is only a single space object, the largest fragments that survive re-entry 

are predicted to be 220lbs. This is a near-term reminder that we should keep a vigilant eye on space-related safety as we look to launch thousands of objects over the 

coming years. 

The positive news is that space safety can be straightforward when thoughtful, 

common-sense rules are applied. Operating costs and engineering challenges may 

increase slightly, but abiding by such minimum rules ensures satellites will continue to play a larger role in the Nation’s and the world’s communications ecosystem, and that the American space sector will continue to grow. 

We look forward to working with the Committee, other stakeholders, Federal regulators, and others to address these issues and ones yet to emerge. 

Conclusion 

Mr. Chairman, Ranking Member Nelson, and Members of the Committee: thank 

you for the opportunity to testify today. As you have seen, we are on the cusp of 

bridging the digital divide using new incredibly high-performance satellite technologies. 

We know you understand the moral urgency of this mission. We know you see 

the issues as you visit rural townships and populations, where millions of Americans live without access to quality education, telemedicine and entrepreneurial opportunities. 

We are not here to ask you for Connect America Funding or other government 

subsidies. OneWeb was able to raise its funding because its novel technologies can 

sustainably achieve this goal without relying on such subsidies. 

We are here to stand by your side, and with many others, help bring connectivity, 

jobs and economic prosperity to rural America and the world’s rural populations. 

STATEMENT OF HON. ROGER F. WICKER, 

U.S. SENATOR FROM MISSISSIPPI 

Senator WICKER. Thank you very much. And thank you to all of 

our witnesses. 

Mr. Dankberg, let me begin with you. As you know, I’m from a 

rural state, and many members of this Committee are from rural 

states, and we are very much interested in bridging the digital 

broadband divide in those areas. 

Recently, Senator Cortez Masto and I introduced the Streamlining Permitting to Enable Efficient Deployment of Broadband Infrastructure Act, the SPEED Act, and it deals with the permitting 

process for deployment of broadband. This will give—this will help 

accelerate deployment in rural America in such areas as 5G. 

As you know, Congress and the President are working on infrastructure, and we would like to deal with that as soon as we get 

through with the tax packages, our next big issue. 

What are your thoughts on how Congress can ensure that satellite providers can be included in any broadband infrastructure 

proposal? 

113 

Mr. DANKBERG. Thank you, Senator Wicker, for your question. 

We are very anxious to participate in delivering broadband more 

to rural America. The thing that we would find the most useful 

would be to have a technology-neutral policy which would allow 

whatever infrastructure investment is made to deliver the greatest 

amount of broadband service to the greatest number of people with 

the best service at the lowest prices. That would be our suggestion 

for getting the most value out of investment that we make. 

Senator WICKER. Well, OK. Technology-neutral in terms of where 

we put the investment, should this be done at the FCC level or according to the statute? 

Mr. DANKBERG. Yes, and one of the opportunities, and the CAF 

program, the Connect America Fund program, has been mentioned 

already. The Connect America Fund program has a concept of a reverse auction where different providers using different technologies 

could make bids to say, ‘‘How much would it cost to deliver this 

broadband to this area with these features?’’ And there are different technology attributes that the FCC has looked at: one of the 

dominant ones is speed, another one is bandwidth, a third one is 

latency, a fourth one is price. 

What we see in the market—and our experience in the in-flight 

connectivity business is a good example of this—is that the things 

that really dominate users’ perception of the quality of broadband 

is the speed of service that they get and the amount of bandwidth 

that they get, that is, not having to have usage caps that would 

limit the amount of bandwidth that they use. And the next one 

would be, it’s tied to both of those, would be price. 

So our recommendation would be to use something like a reverse 

auction process, but to use market-based factors that would reflect 

the desires of subscribers for getting the best service that they can. 

And that would also allow the government to achieve the greatest 

penetration of subscribers that is possible, given that amount of 

money. 

Senator WICKER. Are we going to need to amend the statute on 

that, or does the agency already have the authority? 

Mr. DANKBERG. So far, our perception is that the FCC has not 

weighted it in a market-reflective way, that the weighting that 

they’ve put on latency is so high that a satellite service—I’m going 

to give you an example—a satellite service that would deliver one 

or two hundred megabits per second at a given price and to more 

people would be penalized so severely that a lower latency service 

of even 10 or 25 megabits per second may be selected in the auction. We don’t think that those weighting factors accurately reflect 

what subscribers really want in a broadband service. 

Senator WICKER. Ms. Cooper, were you wishing to weigh in on 

that issue? 

Ms. COOPER. Yes. Thank you, Senator. We agree that there is 

some review needed of any program that’s looking at broadband 

partly because you want every tool available to you as you try and 

reach every citizen in your state. 

For the Connect America Fund, we found for us the latency issue 

is not our chief concern because we believe our low Earth system 

will have latencies in 25 to 35 milliseconds. But we found an area 

where satellites have simply been precluded from bidding because 

114 

the last generation of satellites didn’t meet some of those speed and 

latency requirements. So instead of a wholesale exclusion of an entire category of technology, we would just recommend that the 

Committee look at any of the programs or Federal incentive or infrastructure programs to ensure that anything that qualifies, any 

technology that meets those requirements, can bid. 

I would just say that satellites are sort of structured differently 

in that the incentive is not to build the infrastructure. All the companies here are investing and building in the connectivity. The infrastructure on the ground, whether it’s to an end location, a terminal for the consumer, or potentially some gateways to manage 

traffic, is where that sort of scale is going to come in, and we may 

end up coming back to you with some recommendations to make 

sure those elements can be captured as well. But none of us here, 

certainly not SpaceX, are counting on that investment in our space 

constellation to come to fruition. 

Senator WICKER. Thank you. 

Ms. Cortez Masto, it appears you are next. The last shall be first. 

Senator CORTEZ MASTO. Thank you. Thank you, Mr. Chair. I 

know my colleague Senator Sullivan has to preside, so I defer to 

him. He wanted to ask a question. 

STATEMENT OF HON. DAN SULLIVAN, 

U.S. SENATOR FROM ALASKA 

Senator SULLIVAN. Thank you, Senator Cortez Masto. 

Mr. Chairman, I just have one quick question before I go preside, 

and it’s to Mr. Wyler. 

Mr. Wyler, you talked about space debris, and Senator Booker 

and I have had some concerns about this. The Department of Defense Space Surveillance Network currently tracks 22,000 pieces of 

orbital debris that no longer serve a useful purpose. 

Can you—and perhaps, Ms. Cooper, if you want to weigh in on 

this—can you talk about what your concerns are? And of the Federal agencies we have tracking this, nobody seems to be in charge. 

Who should be in charge? 

Mr. WYLER. Thank you for the question. It’s very important, Senator Sullivan. One, if there is a collision of satellites, we will—all 

the opportunities you heard today, all the wonderful things we 

could do for humanity and rural populations will vanish in the 

blink of an eye. We cannot have that. We have to make sure that 

all of the satellite systems have their own altitudes, that they’re 

not all at the same place physically at the same time. 

And so while we’re tracking 22,000 space debris, a huge number 

of space debris was created at about 800 kilometers a few years ago 

when Iridium and Cosmos satellites hit each other, creating thousands of new fragments to track. These fragments then hit each 

other again and create new fragments, creating more and more 

space debris. As space debris numbers rise, they will impact and 

have impacted many other satellites. 

So the important thing to do, first of all, is to just keep things 

separated. Make sure everybody is at their own altitudes, like airplanes, or cars driving on other sides of the roads. This is a physical issue. 

115 

Now, who should oversee this? That’s a very interesting question. 

Right now, the FCC does not have the tools to do it. NASA is 

studying this at great length. And the FAA is looking into it. It’s 

really up to you, in the Congress and the House, to determine what 

we should be doing next and to form some sort of a committee and 

oversight and take the lead for America in what needs to be done 

because we will lead this for the rest of the world, which is asking 

the exact same questions. 

Senator SULLIVAN. Thank you. 

And, Mr. Chairman, I’d like to yield back full-time to Senator 

Cortez Masto, who was kind enough to let me skip in line so I can 

go preside. Thank you. 

The CHAIRMAN [presiding]. Thank you, Senator Sullivan. 

And we’ll go to Senator Cortez Masto. 

STATEMENT OF HON. CATHERINE CORTEZ MASTO, 

U.S. SENATOR FROM NEVADA 

Senator CORTEZ MASTO. Thank you. Thank you, Mr. Chair. 

Thank you all first of all. Great conversation today. As you know, 

I’m from Nevada, 17 counties, 15 of which are rural, and rural 

broadband is so important. So I think this conversation is incredible. I’m very excited about the future. 

I want to follow up on the line of discussion that we’ve had, 

though, about the use of reverse auctions and the process that 

should be allowed to reflect the consumers’ wants. And I appreciate 

you bringing up C-band with latency and price. 

Can you talk a little bit about how proposed satellite Internet offerings and what they provide to consumers? Do your proposed satellite Internet offerings provide consumers with unlimited 

broadband access, or are there going to be data usage caps imposed 

to manage that capacity? I’ll ask all of you, whoever. Yes, thank 

you. 

Mr. DANKBERG. OK, yes, I’ll start with that. Yes. So we have 

plans of both types, we have both effectively unlimited plans, and 

we have plans that have usage caps. The plans that have usage 

caps, we try to set the usage caps at levels that most people would 

not hit. What we have found in the market is that hitting the 

usage caps is basically the greatest source of dissatisfaction for 

users, so in our new satellites, what we’ve done is we’ve put—and 

I mentioned this in my testimony—we’ve put more than double the 

bandwidth that we had in our first-generation satellite and our second one. The third generation that we’re building is 10 times. 

And the upshot of all that is that we’re working on plans that 

will eliminate usage caps for more and more of our subscribers, 

that we’ll be able to go to market with competitively priced plans 

without usage caps. 

Senator CORTEZ MASTO. Thank you. And that was my follow-up, 

was, Is it going to be cost competitive? And that’s the intent, is to 

be cost competitive and do away with the usage caps is what I’m 

hearing. 

Mr. DANKBERG. Yes, yes. That is—that is exactly right. 

Senator CORTEZ MASTO. OK. I’m happy to hear from—— 

Ms. COOPER. Thank you for that question. I think, like ViaSat, 

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lems. And the limiting factor here is the amount of capacity that 

you have on orbit that you can share among your consumer—consumers and customers. For our part, we are looking at pushing the 

boundaries of the capacity of each satellite and then, of course, 

having many of them, over 20 in view from any spot in the U.S. 

So customers can aggregate capacity where there is a concentration 

of demand and diffuse capacity where those end users are different, 

more widely geographically dispersed locations. 

By building more capacity on orbit, we’ll be able to network— 

manage our network and groom our capacity in a different way. We 

are still several years away from providing customer service, so we 

can’t answer with the kind of specificity that ViaSat can with their 

existing customers, but the real trick that we’re focused on now is 

removing the upper limit of capacity constraints that drive those 

kinds of network management questions. 

Senator CORTEZ MASTO. Thank you. I didn’t know if the 

other—— 

Mr. SPENGLER. Yes. Intelsat is a bit different than other—others 

on the panel today. We are a business-to-business provider, we’re 

providing infrastructure to operators: it could be a wireless operator that is looking to extend services into remote and rural areas, 

it could be a provider of WiFi in-flight broadband, or they use our 

network. 

So our responsibility and our focus is developing that infrastructure that is extremely efficient and very cost effective, delivering 

the speeds that those providers need. 

Senator CORTEZ MASTO. OK. 

Mr. SPENGLER. And so the end user customers are really the customers of our customers and partners. 

Senator CORTEZ MASTO. OK. 

Mr. WYLER. So all this talk of subsidies is confusing for me as 

a entrepreneur. We’ve raised billions of dollars and are raising billions more because we are building a system that can operate and 

meet the needs of people, not meet the needs only if the government gives us money to help it meet the needs. 

Now, I cut my teeth in Africa building systems for people who 

made two dollars a day, you know. So they, of course, couldn’t afford subsidies, but we had to build a system that could meet their 

needs, right? Because in those countries, they don’t have anybody 

giving them anything. So if we were to raise this kind of money to 

build a system, it really needs to be able to operate without subsidies. It needs to be able to provide services at affordable rates for 

the people in these communities. 

So that’s where all the subsidy conversation—I think we’re in 

this point where it’s like subsidy is a given, now let’s figure out 

how to dish it out. Well, why don’t we invent technologies that 

doesn’t need—that don’t need subsidies, like most every consumer 

product people in this room today buy? So this is where I’m sort 

of trying to figure out, I think we’re taking the subsidy as a given 

as opposed to saying maybe we should have technologies that don’t 

need it, and focus on that. 

Senator CORTEZ MASTO. And your technology is one that will address the consumer’s need and the consumers’—— 

Mr. WYLER. We’re addressing market—— 

117 

Senator CORTEZ MASTO. Yes. 

Mr. WYLER.—where the hardest hit—this is where I spent my 

time—we’re addressing the system to focus on the people in the 

most need and to do it in a profitable way, to meet their needs, and 

provide broadband that gives them oxygen-like capacity. They 

wake up in the morning, they have it, they don’t think about it, 

just like we take every breath every day. 

Senator CORTEZ MASTO. Thank you. 

I notice my time is up. Thank you very much. I appreciate you 

being here. 

Thank you, Mr. Chair. 

The CHAIRMAN. Thank you, Senator Cortez Masto. 

Senator Hassan. 

STATEMENT OF HON. MAGGIE HASSAN, 

U.S. SENATOR FROM NEW HAMPSHIRE 

Senator HASSAN. Thank you, Mr. Chair. And thank you and the 

Ranking Member for holding this hearing. 

And to our witnesses today, thank you so much for being here 

and for the work you do. 

Mr. Wyler and Ms. Cooper, I just wanted to start with a question 

for the two of you, and, first of all, thank you for your testimony. 

I come from a very rural and geographically diverse state. We’re 

small, but we’ve got mountains, we’ve got seacoast. And just a few 

weeks ago, thanks to the Chairman and Ranking Member, we had 

a field hearing in New Hampshire to explore the issue my constituents face when it comes to connectivity. And one of the more humorous parts of the hearing was when one of the providers said we 

have to be careful not to build duplicative capacity, and my constituents were like we just would like capacity, you know, we’re not 

worried about duplication yet. 

So I guess the question is, How can satellite provide a broadband 

solution for states like mine? And what’s the role of satellite in a 

5G America, especially with so many of our places, even though the 

maps may say we’ve got connectivity, but in reality, our citizens 

will tell us they don’t? 

So, Ms. Cooper, why don’t we start with you. 

Ms. COOPER. Thank you. That’s a terrific question. I think it’s 

the problem that all of us here are geared to solve using different 

architectures and different technology approaches, but I think it 

underlies the goal that all these companies here on the panel have. 

For us, we are looking at these constellations of satellites with 

multiple satellites in view so that you’re not bound to one single 

path to reach a specific satellite. You would have multiple paths to 

multiple satellites, which we think will allow some currently 

blocked customers to have access to an infrastructure of high-speed 

capability and reliability. 

And then the next step is to make sure that the customer can 

afford a service that is appropriate to what their demands are, and 

that’s the next step, of ensuring that you drive the cost down of 

making lots of satellites, which is I think a strong suit of SpaceX 

and using our manufacturing and innovation history to drive the 

costs of other complex satellite and launch systems downward. So, 

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and also then the cost of deploying those systems has to be driven 

down, certainly a factor of our launch heritage and our reusability. 

So all those pieces bring to bear these two problems. One of them 

is making sure you actually can reach the customer, and the second is making sure that the infrastructure that you’re building that 

will be available, always on, is costly—cost effective and easily deployed from an architecture perspective. That’s I think our approach. 

Senator HASSAN. Thank you. 

And, Mr. Wyler, did you want to comment? 

Mr. WYLER. Sure. Sure. Growing up in Boston on the border of 

New Hampshire and spending all the weekends there, I know—I 

know your state well, and I understand the issues and the challenges, especially when you get in the White Mountains where you 

actually can’t see through the mountain to hit satellites. And so 

lots of people—and this is sort of the same problem in Alaska and 

a lot of the northern states—— 

Senator HASSAN. Right. 

Mr. WYLER.—with a lot of satellites, you can’t see, you literally 

just can’t see them. 

So our satellites remain very high in altitude, almost straight up 

at all times, so you always have a vision of one or two or multiple 

more satellites at a time. 

The key is the terminal. The key is to have something small, 

lightweight, inexpensive. And the size is actually less important 

than the weight and the cost. And that’s where people get—no one 

in rural New Hampshire, they’re not going to care whether it’s 1 

foot, 2 foot, or 10 feet. They’re going to care, ‘‘Is it cheap? Can I 

install it easily? And do I get really good Internet access?’’ 

Senator HASSAN. Right. 

Mr. WYLER. So what we’re doing is bridging—we’re flipping rural 

on its head. We’re making rural faster than suburban, and so it’s 

no reason that rural has to have that penalty. 

Senator HASSAN. OK. Thank you. 

And, yes, Mr. Spengler. 

Mr. SPENGLER. Yes, I just wanted to add to that. I think we all 

believe that to bridge the digital divide, it’s going to take a combination of a lot of different technologies to get there. It may be direct-to-consumer by satellite, it may be enabling terrestrial networks in new ways. 

But I think people don’t realize today that satellite is currently 

in the backbone of a lot of wireless networks around the world who 

are providing 2G and 3G services in lesser developed countries. 

And Intelsat today is providing 4G services, helping wireless companies extend their network in 4G in the U.S. So 5G is an extension of that. 

And we firmly believe that when it comes to rolling out 5G across 

the country, it is not going to get everywhere without the support 

of satellite, and satellite solutions are going to be essential to 

reaching those hard-to-reach locations and extending those capabilities out there in the future. 

Senator HASSAN. Thank you. 

And, Mr. Dankberg, did you have anything to add? 

119 

Mr. DANKBERG. No, I think that satellites today, if you look at— 

we think a great model is satellite TV where 30—over 30 million 

people have satellite TV. And our ability to provide satellite Internet basically corresponds exactly to satellite TV, a competitive service. 

Senator HASSAN. Well, thank you. I see my time is up. I have 

two other questions that I’ll submit to you for the record, one about 

planning for resiliency in the light of natural disasters, and the 

other about debris in space, and I look forward to your answers. 

Thanks. 

The CHAIRMAN. Thank you, Senator Hassan. 

Senator Nelson. 

Senator NELSON. I saw firsthand what satellite communication 

does in a place like Puerto Rico, since so much of it was—you 

couldn’t communicate because there wasn’t electricity, even though 

they were bringing in temporary cell towers. So I was provided a 

satellite phone when I went. 

I’m curious as we’re going forward, talk about the role that your 

satellites will play with regard to something like autonomous vehicles. 

Mr. SPENGLER. I can start. So as I mentioned in my opening remarks, we see satellite as playing a important role in the connected 

vehicle. And, again, the connected car is not just going to be connected by satellite, it’s going to be connected by all sorts of wireless 

technologies, as it is today, and we know the cars are getting more 

and more sophisticated. 

So it’s leveraging each communication’s technology for its particular role and leveraging its strength to provide a safe environment for cars and safe environments on the roads that will ultimately lead to the fully autonomous vehicle. 

What we’re working on is a technology partnership with an antenna company that will shrink satellite antennas so that they’re 

small enough to fit into the roof of a car, the company is called 

Kymeta, and this will enable software download to mapping 

downloads on a point-to-multiple-point basis to thousands and 

thousands of cars at one time. Keeping that data up to date is 

going to be essential for safety and enabling those future features 

in cars. 

Senator NELSON. And how does that integrate with the GPS system? 

Mr. SPENGLER. Well, GPS, of course, is connecting cars today, 

and it already exists. And so it is all going to be tied together 

through software and systems in the car at one point in time to 

make sure that they’re all working together to enable a safe environment for passengers on the roadways. 

Senator NELSON. And as you answer, Mr. Wyler, also bring in 

spectrum. There’s a real competition for spectrum by terrestrialbased broadband services as well as satellite. So what’s the right 

balance? 

Mr. WYLER. Excellent question. And I like that you started this 

off with the first responder because this was actually an initial 

focus. We put a lot of resources into developing an antenna that 

would go on the top of a car or be built in, which also includes LTE 

and 3G connectivity for the passengers in the surrounding area. 

120 

And a unique feature of this for a first responder. So imagine a 

fire vehicle, a fire truck, and you put the antenna on it, and wherever you go, when the AT&T or Verizon signal falls down, it’s listening to the signal strength, and it turns on in milliseconds, maintaining your call. It tells your phone, ‘‘Hey, I’m here, I’m your local 

antenna,’’ when the signal strength is low, and then when the signal strength comes back up, it automatically shuts off. 

A unique feature of this is as the vehicles come together, they actually know where each other are and form their own network. So 

you could walk among the vehicles with your normal cell phone 

and be using your current cellular operator, whichever you have, 

in any country of the world. 

So this would be unique and important for places like Puerto 

Rico, for instance, and Florida, where a hurricane comes, and every 

police officer and every fire vehicle and every emergency vehicle 

will actually be its own cell system with the resiliency that satellite 

brings it. 

Senator NELSON. So, Ms. Cooper, now, there are a dozen applications in front of the FCC for various new satellite constellations. 

So what challenge does this pose to your company? And how are 

we going to have coordination and spectrum-sharing protocols in 

the future? 

Ms. COOPER. Thank you, Senator. Part of that space renaissance 

that I referenced is an excitement about using this concept of low 

Earth orbiting satellites to solve complex problems on Earth. There 

were 32 different proposals filed at the ITU, and 11 of those companies have filed either to ask for a U.S. license for their constellation, such as ours, or a license to provide a foreign system with 

service to the U.S. 

Not all of those will succeed. This is a complex set of problems. 

There’s an engineering and design and investment and concept and 

bring-to-market problems that all need to be kind of brought to 

bear. 

Companies like SpaceX love to solve these kinds of difficult complex problems, and we think we have a real edge because we can 

draw through our design and manufacturing technique and our 

launch capability to deploy this kind of system. 

The FCC has done a terrific first step to review and update the 

rules for this kind of satellite constellation, which hadn’t been updated in about 15 years. And they rightfully put the onus on sharing spectrum on the operators to share and negotiate and coordinate. And if they can’t come to agreement, the FCC will designate 

and split the bands. Every applicant in the round said that is the 

least effective outcome, is to have the FCC dictate and divide and 

designate spectrum. So the best outcome will be between smart 

systems, better incentivized to continue to innovate, and 

incentivize to continue to coordinate. 

And this is also true internationally. The ITU has similar encouragements internationally for other governments to apply for 

systems to coordinate operator to operator, and make the best use 

of the airwaves by applying those negotiations and smart technologies. 

Thank you. 

The CHAIRMAN. Thank you, Senator Nelson. 

121 

Senator Gardner. 

STATEMENT OF HON. CORY GARDNER, 

U.S. SENATOR FROM COLORADO 

Senator GARDNER. Thank you, Mr. Chairman. 

And thank you all for your testimony and time today. This is an 

incredibly exciting technology that we continue to develop and that 

you continue to deploy, and I thank you for it. 

It used to be when I was growing up that satellite communications had sort of a James Bond feel to it. If you saw a satellite 

phone, it was the size of a cinderblock, and it was really amazing 

that you could see that. We advanced then to, you know, cell phone 

technologies and the bag that dimmed the headlights on the car 

when you plugged it in. So then, you know, we see this—what I 

think you’ve done is sort of the democratization of satellite technology through broadband deployment, and it’s incredible, particularly for a state like mine, where we have vast swaths of rural 

areas from the high plains on the east side to the beauty of the 

mountains and the valleys as a result, and some of the challenging 

terrain when it comes to communication on the western part of 

Colorado. 

And so, Mr. Dankberg, obviously I greatly appreciate your presence in Colorado, the work you do, the hundreds of employees that 

you have there. I appreciate what you do to help connect all of us. 

My staff informs me they are not pleased with your connections on 

in-flight satellite efforts because I can send them e-mails and articles and they’re very upset at that. 

[Laughter.] 

Senator GARDNER. But I appreciate it, so thank you. 

In the 1980s, your business was started and grown dramatically 

since then. You talked about in-flight satellite. We’ve had talk on 

autonomous vehicles, vehicle-to-vehicle communication, what satellites can do in terms of that. What other areas can satellites provide for that unique niche, too, as well as satellite technologies may 

be preferred in certain circumstances? If you can talk about those 

two ideas. 

Mr. DANKBERG. Yes. Thank you, Senator Gardner. And also 

thank you for your leadership on the AIRWAVES bill and your recognition of the importance of satellite. 

One of the areas that we haven’t talked about very much is our 

national defense and homeland security. And satellite provides a 

capability to connect people anywhere and to protect them. And 

there are many applications that we do for the Defense Department with satellite communications. We identify the locations of 

friendly troops and avoid fratricide, it’s a very important application. 

One of the things I mentioned in my testimony is that we provide 

Internet connectivity to the entire U.S. VIP fleet, including Air 

Force One and Air Force Two, so that the leaders of our country 

can remain in contact with the ground no matter what’s going on 

and get up-to-date information over the Internet. 

Another really, really important one is for our troops overseas. 

And so one of the big advantages of the satellites that we’ve developed that have so much more bandwidth than conventional satVerDate Nov 24 2008 13:09 Mar 27, 2019 Jkt 000000 PO 00000 Frm 00125 Fmt 6633 Sfmt 6601 S:\GPO\DOCS\35753.TXT JACKIE
122 

ellites is that we can make very, very small terminals and put 

them on platforms like helicopters. And so V–22, Marine Corps, 

now has the ability to remain in contact with their troops while in 

flight at broadband speeds. We also provide support for Border Patrol as well, whether it’s in the oceans or over deserted areas. All 

these areas are very uniquely suited for satellite. 

And then the other point is the types of satellites that we’re 

making are so new that the amount of bandwidth we provide is on 

the order of 100 times that which is available through organic DoD 

satellites. So the Department of Defense is a very heavy user of 

commercial satellite systems, especially ours and the networks that 

we provide. 

Senator GARDNER. Well, you think about the advancements, if 

you go through some of the documentation of September 11, 2001, 

and you talk about the experience that President Bush was having 

on Air Force One while they were watching what was happening 

on that day, they were relying on over-the-air transmission, right? 

Mr. DANKBERG. Yes. 

Senator GARDNER. They didn’t have a feed that could give them 

consistent reliable communications to watch the news to see what 

was unfolding. Now, of course, you can provide that. So I think, 

again, just the national security component of this is so critical and 

shouldn’t be overlooked. 

Ms. Cooper, you talked a little bit about the constellation efforts 

that you’re making at SpaceX. You mentioned in your testimony 

that there will be prototype launches over the next several months, 

and if you need the space for launch, we certainly have plenty of 

space for launch in Colorado. 

With the launch campaign beginning in 2019 with phases of satellites launching through 2024, I mentioned the wide swaths in 

Colorado. If low-latency, high-speed satellite constellations were an 

option for rural constituents in Colorado, it would mean obviously 

a big step in overcoming the digital divide. When do you think constituents like mine in rural Colorado, rural America, could benefit 

from this? Would they see it in 2019? How long would it take? 

Would they be the first to benefit from this? How would that look? 

Ms. COOPER. So our current deployment plans have us sending 

up two test satellites within the next few months so we can verify 

the technology we’ve been designing and building from scratch, and 

then starting our launch campaign in about 2019, and launching 

the entire constellation over the course of about 5 years. So we 

would expect to provide commercial service, as early as 800 satellites deployed, which is probably in the 2020–2021 timeframe. It 

certainly would be available throughout the United States including in Colorado. As a Kansan, we’d like to help you out. 

Senator GARDNER. Well, just don’t take our water, that’s all I 

ask. 

[Laughter.] 

Senator GARDNER. So just the final thing, and I’ve run out of 

time here, is CAF-II, you mentioned tech-neutral language for 

things like CAF-II funding. I think it’s very important. I didn’t get 

a chance to ask that. I asked you and Mr. Dankberg the same 

question. But I think that’s very important, that we have to make 

123 

sure that tech neutrality remains a central element of the work 

that we do. 

Thank you for your time. 

The CHAIRMAN. Thank you, Senator Gardner. 

Senator Inhofe. 

STATEMENT OF HON. JIM INHOFE, 

U.S. SENATOR FROM OKLAHOMA 

Senator INHOFE. Yes, thank you, Mr. Chairman. Being new on 

the Committee, I’m not as familiar as some of the rest of mine, 

with these issues. However, Mr. Dankberg, I have been the Ranking Member on the Senate Armed Services Committee, and we very 

interested in the applications that we have and that we enjoy. How 

are we with our competition over there? Tell me who else is out 

there that we’re competing with in this realm. 

Mr. DANKBERG. Which other nations? 

Senator INHOFE. Yes. Well, adversaries. 

Mr. DANKBERG. Adversaries? Yes—— 

Senator INHOFE. I won’t make you—I won’t ask you to make that 

determination as who are our adversaries, but go ahead. 

Mr. DANKBERG. Yes. So satellite has been very, very instrumental in use in the Middle East and in Africa in dealing with 

ISIS and terrorists in terms of surveillance and reconnaissance. 

The issue is that now we’re dealing with potential and more nearpeer adversaries, and we have a number of issues and 

vulnerabilities. And so the things that I have described that provide more bandwidth to end users also provide more resilience and 

jam protection to our forces in the field. 

The good thing is that largely because of the American system 

and the opportunities in the U.S., the U.S.—this is really important, I think. This is an area, the types of technology that you’ve 

heard from everybody on the panel, is an area where the United 

States has clear technology leadership over pretty much every 

country. And we do work internationally, including all of the countries, including some that may eventually be adversaries. 

I think that making spectrum available and providing a supportive environment for satellite will keep us in the lead relative 

to all of our adversaries. I think we do have a strong lead now in 

satellite communications. 

Senator INHOFE. Yes. Where are we with Russia right now? 

Mr. DANKBERG. Again, so the Russians—the underlying technology that we have described, all of us are describing, is what’s 

called spot beam satellites. The spot beam satellites basically reuse 

frequencies extremely efficiently. You’ve heard about that, LEO 

and GEO. 

Senator INHOFE. Yes. 

Mr. DANKBERG. No other country has the technology yet that we 

do for spot beam technology, probably a factor of 10 behind what 

we’ve been doing in the United States. But I can tell you that Russia, China, India, Brazil, all of the space-faring nations are very, 

very interested in this, and if we don’t support our satellite industry, I feel that we could fall behind. 

Senator INHOFE. Yes. Mr. Spengler, did you want to make a comment? 

124 

Mr. SPENGLER. Yes, I just want to add just something to that, 

and I agree with everything that Mr. Dankberg said about the importance, the tactical importance, of satellite communications to 

military missions for our military. But just maybe to take his last 

thought a little bit further. It is vitally important that the commercial satellite industry is integrated into the strategy and planning 

of military SATCOM as well. 

Senator INHOFE. Yes. 

Mr. SPENGLER. And what we’ve seen over the time period of recent conflicts is how critical the commercial industry has been to 

those missions, and we think that it needs to be sustained in a 

very resilient way, that we can integrate strategies commercially 

and with MILSATCOM to provide this leadership well into the future. 

Senator INHOFE. OK. I appreciate that. 

Mr. Dankberg, I appreciate also what you’re doing in my State 

of Oklahoma. We’ve got some 20,000 homes with you, and, of 

course, when you put this on American Airlines, all the installation 

takes place in my home city of Tulsa. And I know that some of the 

rest of you are actually launching satellites right now to reach 

some of the rural areas which I’m concerned about in Oklahoma. 

But, Mr. Wyler, I know that you’re not—it’s not the same company you had when you and I talked before, when you were talking 

about your activities in Africa, and it’s a different company now. 

Are you still involved in Africa? And I’d like to use the rest of my 

time having you explain to me—I just got back from Tanzania, 

Rwanda, Burundi, Ethiopia, and I’ve kind of specialized in Africa 

now for 20 years. So I’m interested in the problems they’re having 

over there, how I can be of help to some of these countries, because 

they look to me as one who might be able to help them. So would 

you comment on that? 

Mr. WYLER. Sure. Thank you. Thank you. Africa, obviously, I 

spent a great deal of time there, and the challenges, if you look at 

the 17 SDGs from the United Nations, all these challenges about 

gender equality and water and education, every single one of those 

challenges, the underlying requirement is connectivity. You can’t 

measure it, you can’t manage it, without connectivity. 

And so Africa is just like America in our rural areas. There is 

no ability to bring broadband because the terrestrial infrastructure 

is too expensive. We still spend a lot of our energy with Africa. 

We’ve been working with a lot of African nations. Like the Government of Rwanda is an investor in OneWeb as well as many other 

places around the world. 

So we’re—they’re counting on us to help solve this problem, help 

to bridge this divide, because the cost structure of other technologies is just too high. 

Senator INHOFE. Well, it’s interesting you mentioned Rwanda, 

because I had dinner with Paul Kagame just less than a week ago, 

and he brought this up. This is a great concern there. But go 

ahead. 

Mr. WYLER. Yes, and he’s becoming Chairman of the African 

Union and leading the technological revolution of Africa. So Africa 

is going to have more youth than any other continent in the world 

over the next 10 years. It’s growing very fast in population, but it’s 

125 

also growing in economy. The economics of each country is growing 

really fast, and they’re needing and utilizing more broadband. If we 

stranglehold that broadband in any way, that continent will have 

trouble growing, it will have trouble allowing the youth who are 

hungering for information to experiment and understand. 

Senator INHOFE. Yes. Well, my time has expired, but maybe for 

the record, because a couple other countries have brought this up 

to me, one being the Prime Minister of Ethiopia, and has a great 

deal of interest. 

Thank you, Mr. Chairman. 

The CHAIRMAN. Thank you, Senator Inhofe. 

Senator Peters. 

STATEMENT OF HON. GARY PETERS, 

U.S. SENATOR FROM MICHIGAN 

Senator PETERS. Thank you, Mr. Chairman, and thank you to 

our panelists and for your great testimony here today. It’s certainly 

an important topic and an exciting topic of the future. We appreciate you sharing your thoughts here today. 

This industry has been around a while, and we’ve been in space 

a while, and now we have thousands of active satellites orbiting 

the Earth with thousands more rocket bodies and hundreds of 

thousands of pieces of debris cluttering near-Earth space as well. 

On top of that, the companies that are here before us, you’re 

going to be putting more stuff up into space as well. And so we’ve 

been very fortunate I think so far, we haven’t seen any high-speed 

collisions, or a limited number of those at least, but certainly each 

collision, as you know, exponentially increases the odds of having 

other collisions as a result of the debris that’s thrown out there. 

So, Mr. Wyler, my question to you is that your testimony provided some detail about your debris mitigation strategy and how it 

exceeds the U.S. Government’s best standards, which you cited as 

being outdated, that we currently have. Would you propose that 

the mitigation strategies your company is following, namely, the 

125-kilometer minimum altitude spacing and 5-year limit for 

deorbit could be followed as best practices for the whole industry? 

Mr. WYLER. Oh, for sure. Space debris, as you mentioned, is a 

critical component. And everything we’re talking about doing for 

Africa, it will be gone if we end up with a space debris problem because our orbital altitudes will be gone. So the 125 kilometers, 

which was actually adopted as well by Boeing, and others have 

been keeping orbital separation, is really, really critical to making 

sure that if there is an intra-constellation collision where one operator might have failures of satellites and smash into their own satellites, that those debris will have a limitation on how much debris 

they cast into other altitudes. 

And your own University of Michigan students who now work at 

OneWeb have done a lot of calculations on this to show the tail and 

the falling off. So you have of looking at both debris greater than 

10 centimeters and greater than—less than 10 centimeters, and if 

you look at that, it really starts to dive off around 125 and 150 kilometers, the total amount of debris that makes—when you model 

two satellites hitting each other using the NASA debris orbiting 

models. 

126 

So that separation is critical. It’s just like lanes in a highway. I 

mean, you can’t be going in the same place at the same time. 

So—— 

Senator PETERS. Well, certainly, the benefits are pretty clear, as 

you just articulated. What are some of the challenges for us to be 

able to accomplish that? 

Mr. WYLER. Well, I think it’s really a regulatory question because 

it’s very easy to do, and there are plenty of altitudes for people to 

be in. And everyone knows where everyone else is. So we filed and 

put our satellite constellation out there years before everybody else 

in terms of this renaissance. And the people before us, the 

Globalstar and Iridium, we kept a good distance between them. 

And so most everybody usually respects the filing systems and 

says, ‘‘OK, there’s where these are. I’m going to be away from them 

so I don’t have a chance of any erroneous issues causing a catastrophe.’’ 

Right now, there are no rules, I mean no substantive rules. 

That’s why we don’t even quote the current rules, because it’s really—it’s really not relevant. They were done in 1967, so the Outer 

Space Act, right? 

So the big challenge is for America to take a leadership position 

in this and then call in other nations and say, ‘‘Other nations, this 

is what we’re doing. Would you join us in this? Can we talk about 

this? But we’re already taking these constraints upon ourself.’’ And 

other nations will follow, yearning to. 

I saw at the FCC, because of all these different constellations 

and ideas and concepts that have been sort of put to them, the FCC 

has gotten letters from other nations and other—the European 

Space Agency and other space agencies, saying, ‘‘Please don’t—,’’ 

you know, ‘‘Be very careful. It’s not just your space,’’ right? So we 

have to be careful, but we have to—and it’s a global world, but we 

have to take a leadership position and have every—all these other 

nations follow us, and we have that opportunity today. 

Senator PETERS. I see the other panelists shaking their heads, so 

I want to give them an opportunity to weigh in as well. 

Ms. Cooper, do you want to start? 

Ms. COOPER. Absolutely. I think you would be hard-pressed to 

find a company with more invested in the future of space than 

SpaceX. We certainly count on a space environment that allows for 

future inventiveness and exploration, and we’ve approached our 

constellation with that responsibility in mind. 

I would just add there are a couple other elements to this. We 

absolutely will participate and continue to drive forward the caliber 

of operations and expectations for space operations. 

There are a couple other elements I wanted to add. The first is, 

you know, the design of the spacecraft itself is important, the materials you choose. The spacecraft burns up on reentry. The 

compartmentalization of systems, that you can maintain control 

even if you happen to get dinged by the harsh environment of 

space, your survivability and your resilience in space is important. 

Your concept for how you operate on orbit is also important. The 

ability to maneuver in that sort of sandstorm of space, your plan 

for how to respond if there’s a collision, and how to deorbit at the 

end of your operations are all critical. 

127 

Finally, you have to know what’s on orbit, not just the other 

spacecraft, but the debris, and we would really like to continue our 

conversations that we’ve been having with the Department of Defense and with NASA on how to continue to improve the quality 

of inputs, about our understanding of the space environments, that 

we can maneuver smartly when there is a maneuver. 

SpaceX is designing our satellites to be able to maneuver thousands of times in their lifespan, and we’re bringing to bear the reliability that NASA entrusts for us to take human NASA astronauts 

to the Space Station to bear in that responsibility of operating in 

space. 

I know that the FCC is about to issue some new rules for very 

small satellites, cubesats, micro-sats, particularly the kind that are 

used for experimentation, and we think that’s the kind of leadership role that the U.S. needs to take, not just for the U.S. environment, but for the global space environment, to balance the role that 

space can take for research and inspiration and also preserving 

that environment for future activity. 

Senator PETERS. Well, I appreciate that. My time is expired, but, 

Mr. Spengler, you’ve been—if you can be brief in your concurrence 

of what you’ve heard. 

Mr. SPENGLER. Sure. We’ve been operating in the geostationary 

orbit for decades, and that’s an orbit with hundreds of satellites, 

not thousands, but—and there has been defined rules on how to operate there, and it’s required a lot of cooperation between satellite 

operators to share that space well. 

We took the initiative with several other operators to create the 

Space Data Association to enhance that engagement with each 

other so that in that arc, the industry itself is taking ownership 

and responsibility for sharing information and making sure that 

it’s safe and secure for the long term. 

But now when you’re talking about thousands of satellites in a 

lower Earth or mid Earth orbit, it gets more complex. And I agree 

with Mr. Wyler, I don’t think we can just leave that up to industry 

cooperation, we’re going to need some help and leadership from 

government to help make that a safe and secure environment for 

well into the future as well. 

Senator PETERS. Right. Thank you for your testimony. I appreciate it. 

Senator INHOFE [presiding]. Senator Blumenthal. 

STATEMENT OF HON. RICHARD BLUMENTHAL, 

U.S. SENATOR FROM CONNECTICUT 

Senator BLUMENTHAL. Thank you, Mr. Chairman. 

I’m concerned about some of the reports that we’ve seen from the 

intelligence community and other sources that Russia and China 

and perhaps even terrorist organizations are pursuing a range of 

anti-satellite technology, in fact, efforts designed to threaten our 

military effectiveness and the satellites that may be used for civilian purposes. Other countries are aggressively developing the jamming and hacking capabilities that could cripple our military technology and surveillance, our navigation systems and communication networks. These technologies can be unleashed on civilian capabilities as well, including commercial satellites. 

128 

So my question to each of you is, How concerned are you by the 

potential hacking capabilities of other countries or other hazards 

that may come from them or from nongovernmental threats? 

Ms. COOPER. Thank you. It’s an excellent question, and as a company that operates one of the most technologically sensitive activities—launch capability—we take this very seriously and have deep 

experience and heritage in the protection of those systems that we 

will bring to bear to this satellite system. 

I would also note that the supply chain is a particular vulnerability for space systems. And we have chosen to bring a high percentage of our manufacturing in-house, and maintain U.S. control 

of that, and we’re proud that our satellites will not only be built 

in the U.S., have high U.S. content, they will also be launched on 

U.S. rockets from U.S. soil without any involvement from foreign 

launchers or certainly Russian capability. 

Thank you. 

Mr. DANKBERG. Yes, thank you, Senator. I think it’s a very, very 

important question. Because we work with the military and the Defense Department, we do get support from them on dealing with especially cybersecurity, and we also provide cybersecurity for defense satellites. So we have a good understanding of what the 

threat environment is. But I do believe that for a privately held 

company to deal with state actors is probably asking more than 

those privately held companies are capable of. 

I think the U.S. has taken—has had dominance in space for so 

long that, in some sense, we may take that for granted. And I 

think it’s not something that we should take lightly. 

One of the solutions that we think is definitely possible is the 

types of satellites that we’re talking about for commercial are so 

much less expensive and so much—so easy to replicate, that that’s 

one of the ways that we at least, from a national defense perspective, can obtain some amount of assurance that we’ll have a reliable capability in space is to use, whether in the geosynchronous 

arc or the in low Earth orbit arc, multiple satellites that provide 

the capabilities that we need so we can make the economics of 

damaging our capability in space overwhelmingly expensive. 

Mr. SPENGLER. As a provider to U.S. military, DoD, and other 

applications, we have built our network with the highest level of 

cybersecurity for those specific customer sets, and have a regular 

engagement and dialogue with that sector. So we’re very familiar 

with the issues and the challenges. That has even led us to design 

our current generation, next-generation, satellites, Intelsat Epic, 

with some very specific feature sets that manage and deal with intentional jamming and hacking that can occur on tactical missions 

that could be absolutely devastating if they’re not dealt with 

quite—quite quickly. 

So it is critically important. There’s no question about this. And 

it’s where we have continual focus in these areas. 

Mr. WYLER. So cybersecurity is obviously very important, but I’ll 

bring up something else. China not that long ago shot a satellite 

at 1,000 kilometers from the ground. They’re not the only ones that 

can do it. If you put all these satellites in the same orbital altitude, 

you are literally shooting two birds with one bullet. 

129 

Orbital spacing allows one satellite constellation to have a calamity without involving the other satellite constellations. So as the 

U.S. Government, which has been very active in looking at how 

constellations can provide very high-speed, low-latency connectivity 

for its troops in the field, it should want—I assume it will want 

that resiliency and that capability and that assurance of continued 

service, and not make it really easy for a competitor or another nation to take out the entire thing at one shot. 

Senator BLUMENTHAL. I think these answers have been very illuminating. My time has expired, and even if I had another hour 

probably, we would not have enough time to exhaust all of the important ramifications of this area. But essentially space is lawless 

right now. 

Space is the Wild West, and it’s vulnerable to cyber, to physical 

interference, as you’ve just suggested, with missiles launched either from space or from ground, and we need to be prepared for 

the threats to our commercial and civilian satellites as well as to 

the military satellites that we have there. 

So thank you, Mr. Chairman. 

The CHAIRMAN. Thank you, Senator Blumenthal. 

Senator Markey. 

STATEMENT OF HON. EDWARD MARKEY, 

U.S. SENATOR FROM MASSACHUSETTS 

Senator MARKEY. Thank you, Mr. Chairman, very much. 

We have come a long since Intelsat and Inmarsat had a monopoly, and I always enjoyed back in the 1980s and 1990s, break up 

the monopolies and to make it possible for there to be more competition. And we have come now to a new era, and this requires 

a lot of thought in order to unleash all of the potential for good 

which is out there. 

So, Mr. Wyler, if I can begin with you, you have raised a lot of 

money, you are going to deploy a lot of satellites. And I guess my 

big question to you is—the softball right across home plate for 

you—what’s the difference between you and all these preceding 

companies that have tried to achieve the very same result in space 

in terms of providing low-cost access to the Internet to citizens, not 

only in rural parts of America, but around the planet? 

Mr. WYLER. Thank you for the question, Senator Markey. I get 

asked this a lot of question—a lot of times. And why now? Why can 

we do it now that we couldn’t do it before, because a lot of people 

have tried? We’ve known the potential, but we haven’t had the 

technology to accomplish it. 

I think it starts—our system, as you had me testify 10 years ago, 

maybe 15, about deploying fiber to the home in Africa, it starts 

with understanding who needs what, and the needs of those consumers and those people in these rural populations, and designing 

for the lowest common denominator of customer. How do you build 

something that’s affordable? We had an earlier conversation about 

CAF funding and all these subsidies. Why are we talking about 

subsidies? We should be building something that’s affordable in the 

first place, to the GDP-adjusted cost structure of the environment 

that we’re going to be serving. 

130 

So what’s happened now is that we’re able to provide a service 

that is very low latency, which is key to the 30—— 

Senator MARKEY. Very low? 

Mr. WYLER. Low latency. 

Senator MARKEY. Low latency. 

Mr. WYLER. Low latency. 

Senator MARKEY. Low latency means what? 

Mr. WYLER. Latency is the roundtrip time between you and the 

server on the other side. So you send a signal up to the satellite, 

down to some gateway, some server, and then back. 

Senator MARKEY. You mean it’s fast. 

Mr. WYLER. It’s fast. 

Senator MARKEY. OK. Yes. That’s another way of saying ‘‘low latency’’? 

Mr. WYLER. Fast, yes. 

Senator MARKEY. OK, fast. 

[Laughter.] 

Mr. WYLER. When you click, it shows up. 

Senator MARKEY. OK, yes, I got it. 

Mr. WYLER. And there are a lot of standards for this. For instance—— 

Senator MARKEY. Our job is to translate into English all acronyms. OK? 

[Laughter.] 

Mr. WYLER. Right. 

Senator MARKEY. So that our constituents understand what 

we’re talking about. 

Mr. WYLER. It’s super critical for things like AR and VR, 

which—— 

Senator MARKEY. For what? 

[Laughter.] 

Mr. WYLER. Sorry. Virtual reality—OK?—and augmented reality. 

Senator MARKEY. Yes. 

Mr. WYLER. So the ability to create a videogame on this table 

while you watch with your new iPhone, this requires very low latency, this—this speed. 

Senator MARKEY. Very—very—it can move very fast. 

Mr. WYLER. Very fast. 

Senator MARKEY. For reality and for augmented reality. 

Mr. WYLER. And for augmented reality. 

Senator MARKEY. Yes. And people can decide which is better. 

Mr. WYLER. Yes. 

[Laughter.] 

Senator MARKEY. Reality or augmented. 

Mr. WYLER. Exactly. 

Senator MARKEY. Yes. We’re actually living in that era right 

now. 

Mr. WYLER. 5G services demand low latency. 

Senator MARKEY. Yes. 

Mr. WYLER. So we’ve been able to create a system that is designed for 5G services so that you can roll out 5G anywhere. 

Senator MARKEY. So when can the first person on the planet be 

expected to be able to subscribe to your service and have it delivered? When do you expect that to happen? 

131 

Mr. WYLER. 2019. 

Senator MARKEY. 2019. And where will that customer be do you 

expect? 

Mr. WYLER. Sitting in Alaska. Hopefully in Barrow or some 

other—not in Anchorage. 

Senator MARKEY. Yes. So you think it will be an American? 

Mr. WYLER. It will be in America. 

Senator MARKEY. OK. Where will the first customer outside of 

the United States be who will be able to subscribe? 

Mr. WYLER. We’ll be covering Europe and we’ll be covering Africa, South Africa, and other areas around there. Also Argentina and 

all around a lot of emerging and rural markets. 

Senator MARKEY. So will all of that be in 2019? 

Mr. WYLER. 2019 will be the beginning customers. 2020 they will 

all be covered. 

Senator MARKEY. So all of Europe will be covered? 

Mr. WYLER. 2020? Yes. 

Senator MARKEY. And not all of Africa, but South Africa? 

Mr. WYLER. Most of Africa will—— 

Senator MARKEY. Most of Africa will be covered? 

Mr. WYLER. Yes. 

Senator MARKEY. Will it be all of South America or just Argentina and—— 

Mr. WYLER. A big chunk in 2020. Most of—most of South Africa—South America will be covered in 2020. 

Senator MARKEY. OK. And, again, this is, you know, commercial. 

And what will it cost the average customer to be able to purchase 

this? 

Mr. WYLER. Well, we’re—well, there are two things: the acquisition cost and the cost of service. So the acquisition cost, if your antenna and your terminal is in the $100 to $150 range, you’re going 

to have real trouble in communities, enabling community infrastructure to be there. If your cost—when I started this company, 

based upon my work in Africa, I shot for, How do we make affordable Internet access for someone who has a two-dollar-a-day income? 

Senator MARKEY. Right. 

Mr. WYLER. Which means 10 cents a day. 

Senator MARKEY. OK. So in 2019—— 

Mr. WYLER. Yes. 

Senator MARKEY.—in 2020 at the latest, you’re on track to get 

this done? 

Mr. WYLER. Yes. 

Senator MARKEY. And you’re going to accomplish it? 

Mr. WYLER. Yes. 

Senator MARKEY. Your investors are prepared to run the risk 

that you won’t be just a repetition of what’s happened—— 

Mr. WYLER. We have a lot of investors and a lot of eyes watching 

us, yes. 

Senator MARKEY. OK. And how many total satellites will you 

have up there? 

Mr. WYLER. In 2020, we should be able to hit about 800 or 900. 

Senator MARKEY. In 2020. 

132 

Mr. WYLER. And then it will climb to probably another—about 

2,000 or 2,200 in 2021. 

Senator MARKEY. So 2,200 satellites. When Motorola was doing 

Iridium, they named it after the 77th element of Mendeleev’s chart 

of elements. They had 77, right? And so you have just vastly expanded it with smaller satellites to ensure that there is ubiquitous 

coverage. 

Mr. WYLER. The key is making these satellites smaller and 

smaller. The—— 

Senator MARKEY. And I think the key question I think for Americans is going to be, Will the price that you’re offering in Alaska or 

rural South Dakota or Massachusetts, will that be on a scale that 

is equivalent to what you’re going to be offering in Africa or in 

South America? 

Mr. WYLER. So we partner with the local providers, the ISPs, and 

let them—work with them to help them set the prices and let them 

set the prices for the hyperlocal environments. So the prices will 

change around the world, but it will be dealt with—the prices will 

be managed by the local—the local Internet service providers. 

Senator MARKEY. So you’re saying you will be partnering with 

Comcast and AT&T in the United States in order to set the price 

for American consumers? 

Mr. WYLER. That’s a great question. They don’t cover most of the 

United States. So we’ll be partnering with a lot of other people. 

And we’re happy to also partner with them, but there will be competition between the partners—— 

Senator MARKEY. So you’re saying in the parts of America where 

you’re going to target, it will be mostly those areas unserved by 

those large ISPs, and as a result, you’ll be partnering with the 

smaller companies—— 

Mr. WYLER. Yes. 

Senator MARKEY.—in smaller towns all across the country and 

trying to devise a price point that will bring a profit to the ISP and 

to you. 

Mr. WYLER. Correct, and to hopefully spur new ISPs and new entrepreneurship in those regions. 

Senator MARKEY. Right. So that very—— 

Do you mind, Mr. Chairman, just so I can understand? 

The CHAIRMAN. [Shaking head no.] 

Senator MARKEY. I appreciate it. So this very low price point that 

you mentioned earlier for, let’s say, Africa or South America, is 

that also going to be something that you’re seeking to achieve that 

to be the lowest cost provider, comparatively speaking, across the 

United States? 

Mr. WYLER. Yes. We’re seeking to be affordable for everybody in 

every state, and so we will hopefully be the lowest cost provider. 

The price will change. It may not be that low in some states, but 

it will be affordable to the people with their local GDP. 

Senator MARKEY. Mm-hmm. Do you have already existing contracts with those ISPs, or are they to be negotiated in the—— 

Mr. WYLER. We have a number of MOUs already with them that 

were set up and ready to go. If you look at our investor base, which 

includes Hughes and includes Softbank, which has a number of 

telecom companies, including Sprint, we’re working very closely to 

133 

make sure we can get rural coverage. It’s a passion and a drive and 

what we’re going to succeed. 

Senator MARKEY. So do you already know what that price point 

is going to be because of the already negotiated contracts? 

Mr. WYLER. We know that we have the flexibility for that price 

point to move to what is affordable within the regions. 

Senator MARKEY. Uh-huh. 

Mr. WYLER. So we actually took a very unique approach to this. Rather than saying, OK, it’s $30 a month or $50 a month, we’ve 

said, ‘‘OK, let’s work together in your region for your area and let 

you set the price because you’re the expert about what’s going on 

in rural South Dakota, you know what the farmers there can afford 

and what they can pay and what the competitive prices are.’’ 

Senator MARKEY. Yes. And so—and, finally, is the service which 

these people are going to receive comparable to the service that 

people receive in Boston? 

Mr. WYLER. I—speaking as a customer of someone in Boston, I 

don’t want to achieve that, better. 

[Laughter.] 

Mr. WYLER. So watching the circle go around. 

Senator MARKEY. No, I hear you. 

Mr. WYLER. So we’ve designed a system that really uses spectrum very efficiently. We’re actually asking the question, Why can’t 

rural be faster? So we’re shooting for 2021 to achieve 2.5 gigabits 

per second of capacity direct to a rural home. So there should be 

no—in the new technological age, there should be no penalty for 

being in rural populations. Those people who want to stay there 

and want to be educated and want to stay with their parents and 

build businesses should be able to, and that’s what we’re trying to 

achieve, and I think we are. 

Senator MARKEY. Well, I saw what you did in Rwanda. You came 

and we had you testify. It was an incredible concept. You executed 

it, and it transformed Rwanda. OK? No one would have ever 

thought broadband in Rwanda would work so successfully. It’s really transformed their future. Hopefully here this concept also is executed because I think the potential is unlimited in terms of transforming information and competition, not just in the United States, 

but around the planet. So thank you. 

Thank you, Mr. Chairman. 

The CHAIRMAN. Thank you, Senator Markey. And I’m glad you 

settled once and for all what latency actually is. 

[Laughter.] 

The CHAIRMAN. We have a whole new way of explaining speeding 

tickets in this country, using high latency—low latency. 

Let me just ask a couple of general questions as we wrap up 

here, to all of you, and feel free to jump in here. What are the 

major factors right now that are affecting investment in next-generation satellite technology? 

Ms. Cooper. 

Ms. COOPER. So at SpaceX, we’re not at this point going out to 

seek outside investment for this project. But I would say the capability to undertake a complex problem is definitely a differentiating 

factor, the ability to not only conceive of it, but actually deploy the 

manufacturing design that’s responsible and undertake the space 

134 

operations in a way that preserves the space environment I think 

are going to be rewarded. 

I think the work that my colleagues here on the panel have done 

in terms of advancing the caliber of satellite services continuously 

over the last few years has also generated an enormous amount of 

investment interest and excitement about what the space environment and what the satellite sector can do. 

Thank you. 

The CHAIRMAN. Anybody else? 

Mr. DANKBERG. I think there are really two factors. One is this 

notion of a space renaissance where there has been a large increase 

in investment in space I think is absolutely true. You see a lot of 

startups. One of the big reasons is because there are companies 

working on reducing the cost of access to space, and that’s basically 

democratizing the environment. 

But there are, I would say, two issues. The number one issue is 

access to spectrum. For communications, no communications system can really achieve the level of cost effectiveness and performance that we want and the level of competition Senator Markey has 

raised without access to spectrum. 

And I think that the real issue here is not dedicating spectrum 

only to satellite at the detriment of some other, it’s really working 

on sharing because there is a finite amount of spectrum, and that 

is a very, very important area. 

I’ll tell you, at the next level down, and it’s not quite as important, is the one that we touched on a little bit here, which is the 

question of subsidies. And the real issue of subsidies, I kind of 

agree with Greg, is that we work on a free market basis. We don’t 

expect subsidies in order to be able to provide a good broadband 

product at a competitive price anywhere in the U.S. We can do that 

without subsidies. 

I do think that we should think about what the effect is of subsidies on market distortion and how that reflects what it is that the 

market really wants, and I think that’s—I wouldn’t put that at the 

level of the spectrum issue, but it’s something I think for the government to consider. 

The CHAIRMAN. OK. 

Mr. SPENGLER. What we’ve encountered in recent years, and it 

has been said many times today, is this renaissance in space and 

satellite communications, and as a result, there is robust investment. There is robust investment in innovation, there are sources 

of capital that are supporting investment, and I think that all ties 

to the recognition that the future network is an integrated network, it’s a single network, it is a telecom network that will have 

many parts to it: satellite, wireless, fiber. And so it is really driving 

a lot of this innovation that’s happening. 

I think the next big area for enhanced investment and free market investment is really on the ground technologies. And it has 

been referenced a few times today, investments have been made on 

satellites and enhancing the performance, the cost, but we also 

have to continue to invest on the ground—the terminals, the user 

devices that customers have, to make them smaller, cheaper, simpler to install, and easy—and that way we’ll be fully integrated. 

The CHAIRMAN. Mr. Wyler. 

135 

Mr. WYLER. So as the only sort of startup in the room, we’ve had 

to go out and raise our share of capital, and we have a very wide 

and broad base of investors. I’ll say sort of the two big things. 

Spectrum certainty, spectrum certainty, spectrum certainty, and 

repeat that so we know it. We should not play with spectrum. You 

should not play with people’s foundations. If you went to Verizon 

and said, ‘‘We’re thinking about taking back the 700 megahertz,’’ 

or whatever, the 1.9, you know, ‘‘maybe it would just halt investment overnight.’’ 

Don’t play with the spectrum. This stuff that we’re doing takes 

7 years to build and tens of billions of dollars to do it at the scale 

we’re talking about. If you play with spectrum, you play with the 

investors’ understanding and viewpoint of the solidity of your 

project, which already has many other dynamics. 

The second thing is space debris. If there’s an accident in space, 

you will see a halt to investment. So unless we take a leading position on this—and it’s not just from the U.S., lots of people can 

launch satellites, we need to take a leading position in the U.S. and 

have all other countries work with us, and they’re eager to do so, 

so that we can keep satellites in their own lanes, because if they 

hit, the whole thing is gone. 

The CHAIRMAN. Right. 

Mr. WYLER. So these are the places where you, on your bench, 

in your position, are speaking not just for investment for the future, but you’re the voice of the people with no way to speak, the 

people in the future generations who also want to have access to 

space, the people in the rural populations who know that this is 

the only way they’re going to get broadband that’s equivalent or 

better than that in the suburbs, and be part of the rest of the world 

and be part of the rest of America economically and socially. 

So those are the two things: spectrum certainty and space debris 

certainty. 

The CHAIRMAN. All of you have talked about how the satellite 

constellations that you have proposed are raising a number of 

issues for the FCC and for various other international entities. But 

do you feel that the FCC has the tools currently that it needs to 

properly address the issues that are raised by satellite constellations along the lines of what you proposed today? 

Ms. COOPER. I would just say I think the FCC has done a laudable job in a very complex issue area. They have just undertaken 

an update of the rules for these kinds of constellations that had 

been sort of dormant since the last generation of low Earth orbiting 

satellites. Those rules will give us a much better platform to kind 

of pivot to this next newer unfolding generation. They did things 

like extending the milestones by which you need to deploy a constellation, which is especially important if you have larger constellations. And as ViaSat has noted, the ability to be able to deploy those is contingent on launch capability, which is something 

we feel very strongly about our capabilities there. 

They’ve also really laid the expectations in terms of sharing spectrum to be firmly on the operators to try and figure out how to 

interoperate with each other, interoperate and protect the satellites 

that are above us, and also make sure that we can work with the 

terrestrial operators. 

136 

The thing that I would say that would be most useful, I think, 

from the Committee in terms of the Commission is to make sure 

there’s a reflection of this opportunity with space-based systems in 

the expectations of spectrum, that there are two kind of key underlying principles. One is you should use, avail, every technology 

that’s possible to try and be a more efficient user of the spectrum, 

and also be incentivized for any group of parties, whether it’s terrestrial and satellite or within the satellite sector at different orbital hierarchies to try to apply technology for spectrum sharing. 

That’s going to serve the American consumer better because you’ll 

get better services through the same amount of frequency bands. 

I think those are the two principles that the FCC is going to benefit from in terms of direction from this Committee. 

On space debris, I think the recommendation for the agencies to 

work together and pool their common and diverse experiences to 

continue to evolve that sort of foremost role of the U.S. in terms 

of maintaining a safe environment, that’s a successful next step. 

We were pleased to see the formation of the National Space Council, we’re pleased to have participation in the first meeting, and expect to be involved in every one of the agencies that’s active in 

space policy. 

Thank you. 

The CHAIRMAN. Thanks. 

Yes, go ahead quickly. 

Mr. DANKBERG. I think the FCC certainly has the skills and the 

resources to manage spectrum. And one of the things that’s helped 

us is the FCC’s willingness to entertain new spectrum-sharing 

strategies within the satellite sector itself. That was part of what 

made our satellites more effective. And then also recently with the 

28 gigahertz spectrum frontiers, the FCC—and we did reach agreement on spectrum sharing between terrestrial 5G and satellite, so 

we know that’s possible. 

I think that especially recently there has been a very strong 

focus on 5G wireless and the FCC, possibly to the detriment of 

other technologies, satellite being one. The other one that I would 

put in a plug for, and this really goes to some of Senator Markey’s 

questions, is we’re a little bit unique because we are a direct retailer. 

So we not only drive down the cost of delivering broadband, but 

we then set the prices to our subscribers. And in dealing with—we 

also deal in Mexico, where we can provide broadband at the price 

points today that Mr. Wyler was talking about in Africa. 

The thing that makes that possible is unlicensed spectrum because when we deliver bandwidth through other carriers, they’re 

the ones, as Mr. Wyler said, that are setting the price points. With 

the access to unlicensed spectrum, we can go to Native Americans, 

Indian reservations, national parks, and deliver services directly to 

people’s phones with unlicensed spectrum. And that’s an area that 

there is really not a very strong advocacy within the FCC. I think 

that that’s one area that could use more support. 

The CHAIRMAN. OK. 

Mr. SPENGLER. I think the FCC, like a lot of regulators that are 

dealing in the digital world have challenges because things are 

moving so fast, there is so much change, and I think that’s where 

137 

industry and the private sector and the market can be of benefit 

in terms of helping solve some of these challenges. 

We’re coming to the FCC with all kinds of new models that we 

haven’t gone to before where we’re talking about partnering with 

different satellite operators, different kinds of arrangements, and 

it’s all to develop new services for different parts of the world, and 

in the U.S. in particular. 

We recently responded to a Notice of Inquiry from the FCC on 

the C-band. And the C-band right now, back to some of the comments that have been made, is being sought after by the wireless 

industry. Currently, it’s being used by satellite broadcasters to distribute programming to cable head ends, to retransmitters all 

around the country, and millions of Americans get their television 

through the C-band distribution. 

What we’ve done is we said, look, we don’t believe that sharing 

can work in the traditional sense, and we proposed a new solution, 

and we proposed a solution with Intel saying let the industry work 

on this together, let the market decide how we can free up spectrum in that band to allow the growth of 5G wireless, which we believe in, we all want that happen, but also give some certainty and 

surety to the broadcasters and the television viewers around the 

country, a scheme where there’s joint use, that the market can decide the best way to clear that spectrum, and that we can bring a 

solution to the FCC. They have a lot of things on their plate, and 

this is one that the industry could potentially solve together in this 

particular case. 

The CHAIRMAN. Mr. Wyler. 

Mr. WYLER. I’d actually slightly disagree with Mr. Dankberg. 

The FCC is probably underresourced in some areas. Just a slight 

disagreement there. Generally, they’ve been doing an excellent job. 

There are places where they are just overwhelmed with new technologies and new ideas, and in this digital age, that changes so 

fast. 

Certainly, I’ll just—you know, in the latest proceeding, the ability for NGSOs to interfere with GSOs, they’ve just given us sort of 

a hall pass and said, ‘‘Go ahead and work it out later.’’ It’s kind 

of interesting because they’re supposed to protect the GSOs. Now, 

being on the beneficial side of that, I shouldn’t be saying anything 

bad about it, but I think it’s a bit—it was generous, let’s say, and 

unexpected to let us do that. 

I think in terms of space debris, they are trying, they really are. 

They’re putting out questions to people with kind of everybody has 

got these different ideas with how they’re going to put their— 

where they’re going to put their satellites and whether they’re 

going to crash into each other or not, and people—and they’re asking them for more data. But they’re not equipped for that, they’re 

not designed for space debris, because they’re a spectrum—they’re 

spectrum focused, right? They’re in electrons, not in physical objects hitting each other. 

So some committee, some way of giving them some tool with 

NASA, with the FAA, with others, maybe a Presidential commission, maybe a congressional or Senate commission, I don’t know, 

but some way of giving them some oversight and some support in 

dealing with this because right now, since—basically their arms 

138 

are tied, they’re frozen, they don’t know what to do with it because 

there is no good answer with the current—if you launched all these 

satellites, you’ll definitely have space debris. So now what do they 

do? And who’s in charge of that? 

The CHAIRMAN. OK. Got it. All right. Well, thank you all. And 

I appreciate very much your—— 

Senator MARKEY. Can I just ask one question? 

The CHAIRMAN. Yes. 

Senator MARKEY. Your questions have been great, so it just 

prompted one question, which goes back to Mr. Dankberg on the 

historic role of unlicensed spectrum and what you think that role 

should be in this space right now. Can you talk about that just for 

a minute, please? 

Mr. DANKBERG. Yes. Thank you. One of the things—if you look 

at some of the things that are really different in the satellite industry compared to, say, 5 or 10 years ago, there are two that are big 

ones. 

One is—and the history of Intelsat shows most of the time satellite companies had to work through other telecom providers because their customers were the telephone companies or the wireless 

carriers. 

The other one is if you wanted to provide video transmission, you 

had to work with a content owner or a TV station for distribution. 

What’s really different now and is very liberating in the satellite 

industry is that you have million—you have billions of phones 

going around which have WiFi capability. So now a satellite operator, if they can deliver a transmission at lower cost than a terrestrial operator, you can create real competition by going to them 

through unlicensed spectrum, but only if that unlicensed spectrum 

is truly available and has the ability to reach those people. 

The other big, big change is that now you’re seeing these overthe-top video services where an individual subscriber can basically 

make an arrangement directly with a service provider, like it could 

be Disney, it could be Sling, Hulu, and that now transmission is 

really a commodity that you can just deliver to that subscriber, 

greatly reduce their cost without having to go through someone 

else. 

So for the first time, satellite is no longer just a cost input to 

somebody else, but it has the ability to compete in two-way transmission. 

Senator MARKEY. So you’re saying, if I may, I just want to put 

it into my consumer perspective, you’re saying that these multiple 

satellite competitors, in an unlicensed spectrum world down below, 

has more potential for identifying markets that they could move 

into and provide services at an even lower cost because that spectrum is unlicensed, and you don’t—the company terrestrially 

doesn’t need a return on investment because it’s unlicensed at that 

point. It’s a much lower cost—— 

Mr. DANKBERG. Yes. 

Senator MARKEY.—overall, and it puts a pressure on the market 

that otherwise would not be there because consumers will be opting 

out and heading in that direction. 

Mr. DANKBERG. Yes, and if I could elaborate just for a second, 

we are doing services in Mexico and in Africa. In Africa, we work 

139 

with an organization called RASCOM, which is an organization of 

all the African states. We need to go through cellular operators 

there. A cellular operator would need to go into a village and invest 

$50,000 to $100,000 to put a cell tower in. In Mexico, we can do 

it directly using our own satellites, and for $1,000, put in a WiFi 

hotspot. 

So that—we’ve talked a lot about technology, which is exciting, 

but the business model changes are very important, and seeing regulations that support those would be very, very helpful. 

The CHAIRMAN. OK. Thank you, Senator Markey. 

Well, great panel, great questions, great answers. It’s a fascinating field, and one that we obviously want to do everything we 

can to support and encourage and see that we are doing everything 

we can to make sure that people all over the country and all over 

the world, in the South Dakotas of this country and other places 

around the world, have access to everything that comes with technologies, and broadband, and the opportunities associated with it. 

So we appreciate the good work that you all are already doing, 

and we’ll look forward to working with you and encourage you as 

you encounter issues, challenges, that you think we ought to be attending to and articulating policy about, to share that with us. But 

this I think has been very, very helpful, and we’ll look forward to 

other opportunities to hear from you again. 

I will just say to our panelists that if you could respond to any 

questions that are submitted by members of this Committee, we’ll 

try our best to ensure that we close the record out in a matter of 

a couple of weeks. So we’ll try and get our Members to get their 

questions for the record to you, and then if you could, as promptly 

as possible, get those responses back, it would be most appreciated. 

So with that, we will conclude. Thank you all very much. 

[Whereupon, at 12 p.m., the hearing was adjourned.] 

(141) 

A P P E N D I X 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. MAGGIE HASSAN TO

PATRICIA COOPER

Question 1. With the recent hurricanes and tropical storms devastating Florida, 

Texas, and Puerto Rico, I’d like to talk a little bit about emergency preparedness. 

If things go according to plan with this industry, in a matter of years our planet 

will be covered with low-orbiting satellites providing broadband to every corner of 

the Earth. That comes with a major responsibility to bring people back on line after 

storms and disasters. How is the industry thinking about emergency preparedness, 

and backup power? Is having an all-of-the-above approach to connectivity that incorporates satellite, fixed, and mobile broadband a good idea to make sure we can rebuild after disasters? 

Answer. Maintaining reliable Internet access in the aftermath of a natural disaster can be critical when carrying out rescue operations, assisting survivors, and 

beginning the recovery process. The unprecedented destruction and humanitarian 

crises caused by Hurricanes Harvey, Maria, and Irma revealed the significant role 

satellite communications play in disaster relief. For those in the affected areas, 

where the existing communications infrastructure was either damaged or decimated, satellite communications provided the initial connectivity for first responders 

and consumers alike. 

When operational, SpaceX’s planned non-geostationary orbit (NGSO) satellite constellation will ensure that its users anywhere in the world can maintain access to 

reliable, high-speed Internet connections, VOIP, and 5G backhaul, even in the event 

of an emergency that disrupts the power grid. SpaceX’s constellation will connect 

its end-users directly to its satellites via small, rooftop mounted terminals, which 

will be available with a small solar panel. This allows for operational connections 

even with local power outages. Additionally, because SpaceX’s satellite constellation 

will be optically linked in space, Internet traffic from the affected area can be routed 

in space to Internet gateways well away from the disaster zone, allowing for 

connectivity even when local communications have been severed. 

An ‘‘all-of-the-above’’ approach to connectivity is important in order to ensure responders, aid groups, government authorities, and affected citizens can maintain 

connectivity after a disaster and in the recovery months following an event. Accordingly, in any future infrastructure legislation, SpaceX supports a technology neutral 

approach to both emergency communications services and more general broadband 

infrastructure deployment. Currently, satellite-based broadband systems are excluded from some sources of Federal infrastructure funding for broadband deployment. The aim of emergency communications and broadband deployment efforts 

should be to multiply the means of broadband access nationwide, and to ensure 

rapid and resilient broadband availability following an emergency—regardless of the 

type of technology used. 

Question 2. One issue this Committee has discussed at previous hearings is the 

issue of space debris. 

According to NASA, there are over 500,000 pieces of debris orbiting the earth. 

This debris ranges in size from non-functional satellites, to fragmented debris as 

small as specks of paint. This debris travels around the earth at speeds of up to 

17,500 miles per hour, roughly ten times faster than a bullet. At these speeds, even 

the tiniest bits of debris can cause damage, and windows on the Space Shuttle were 

replaced because of damage from tiny debris. With the increasing launches of microsatellites and decreasing launch costs it is now easier than ever to launch craft into 

low earth orbit, and the problem is likely to increase many times over. Do you believe that current processes and regulations in the United States are sufficient to 

mitigate the increase in space debris? How can we work to address this issue? 

Answer. In developing its broadband constellation, SpaceX has focused from the 

outset on design, technology, and operations that will preserve and protect the space 

environment for current and future operations. SpaceX is committed to exceeding 

142 

all U.S. and international space safety standards in the deployment and operation 

of its satellite constellation, and to advancing new best practices for safe orbital operations and orbital debris mitigation. This includes leveraging the high-tech manufacturing expertise and spaceflight experience SpaceX has gained providing launch 

transportation services for a diverse set of customers, including NASA and the Department of Defense. 

Based on this experience, SpaceX is incorporating the following best practices into 

its broadband constellation to fulfill its commitment to safeguarding space safety: 

(1) Satellite Design: SpaceX satellites are being designed and built specifically to 

maximize control of a spacecraft throughout its lifespan, even in the rigorous 

space environment. Each SpaceX satellite is being designed with redundant, 

fault tolerant capabilities to ensure they can survive failures and encounters 

with space debris. SpaceX is leveraging its extensive experience in resilient 

spacecraft design, including its heritage with the Dragon crewed spacecraft 

that is undergoing human-rating approvals to transport NASA astronauts to 

the International Space Station. SpaceX is carrying over similar critical 

redundancies into its satellite constellation, shielding its satellites from micrometeorites, and engineering components to withstand an impact in the event 

of a collision. 

(2) On-orbit Operations: SpaceX satellites are being designed to maneuver regularly, both in order to avoid tracked debris and to maintain a safe separation 

within the constellation and with other spacecraft, space stations, and constellations. This ability to process data about potential orbital obstacles and 

autonomously maneuver satellites to avoid a collision is a critical safety element. SpaceX is again able to leverage its experience with its Dragon cargo 

capsule, which NASA has approved to autonomously approach the International Space Station, disembark, and reenter Earth’s atmosphere. This is 

among the most challenging and demanding close-approaches in space. 

SpaceX’s satellites will use on-board, highly efficient solar-electric propulsion 

systems that are capable of autonomous daily maneuvers, adding up to thousands of maneuvers over the course of their lives, in order to avoid potential 

collisions. Even if the risk of impact with space debris is deemed highly unlikely, the satellites will course correct autonomously to avoid the remote possibility of a collision. 

(3) Safe Space Operations: SpaceX is developing a detailed operations plan that 

includes an orderly orbital disposal protocol that maintains control of each 

spacecraft, while rapidly deorbiting. The spacecraft are being designed out of 

materials that will disintegrate in the Earth’s atmosphere at the end of their 

useful lives, reducing risks on the ground. After completion of their useful lifespan, SpaceX anticipates that, typically within one-year, its satellites will reenter the Earth’s atmosphere and disintegrate, far sooner than the twenty-five 

year international standard. 

(4) Government collaboration: SpaceX works closely to coordinate the development 

of its satellite constellation with all relevant government, industry, and international stakeholders. SpaceX has experience working with every Federal 

agency involved in space safety, notably with NASA’s Orbital Debris Program 

Office (ODPO) and the Department of Defense’s Joint Space Operations Center (JSpOC). For the past year, SpaceX has been testing its risk analysis and 

collision avoidance software via a series of extensive debris tracking simulations with JSpOC. This software, in coordination with JSpOC’s orbital debris 

data, will allow SpaceX satellites to maneuver autonomously to avoid collision 

risks—even when these risks are determined to be highly improbable. 

SpaceX is deeply invested in a space environment that is viable for future operations, development, and exploration. We believe that a combination of approaches 

including satellite design, operational responsibility, and collaboration can help ensure a healthy, viable space environment for generations to come. 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. MAGGIE HASSAN TO

MARK DANKBERG

Question 1. With the recent hurricanes and tropical storms devastating Florida, 

Texas, and Puerto Rico, I’d like to talk a little bit about emergency preparedness. 

If things go according to plan with this industry, in a matter of years our planet 

will be covered with low-orbiting satellites providing broadband to every corner of 

the Earth. That comes with a major responsibility to bring people back on line after 

143 

storms and disasters. How is the industry thinking about emergency preparedness, 

and backup power? Is having an all-of-the-above approach to connectivity that incorporates satellite, fixed, and mobile broadband a good idea to make sure we can rebuild after disasters? 

Answer. All types of communications technologies are required to survive and rebuild after natural disasters. Satellite networks are composed of diverse space and 

ground infrastructure providing significant advantages that allows them to remain 

operational during and after natural disasters as compared to local terrestrial communications infrastructure that may be damaged or destroyed and take weeks or 

months to restore. 

Federal, state and municipal public agencies, including FEMA and NGO recovery 

organizations and everyday consumers use satellites to provide robust services and 

business continuity when other networks are damaged, overloaded or unavailable. 

Satellite communications also provides a load sharing or surge capacity solution and 

enable the creation of instant communications infrastructure. 

ViaSat currently has broadband satellite coverage of the continental United 

States plus Hawaii and Alaska, soon to be extended to the U.S. Virgin Islands and 

Puerto Rico. During the recent events in Texas and Florida, the NGO recovery 

teams deployed ViaSat portable satellite broadband terminals to help volunteers 

connect online to provide critical medical support, place people in shelters, and continue to heal the impacted communities. 

Below is a comment from an Exede (ViaSat) customer after hurricane Harvey: 

‘‘I just went through the Hurricane/Tropical Storm Harvey here south of Seguin, 

TX. That storm came within 20 miles of us. How do I know this? Because my 

Exede Internet stayed up the whole time! The winds and rain were ferocious 

and I was quite frankly pleasantly surprised when my Internet connection continued without a burp. I was able to monitor the storm, keep in touch with 

friends and even watch Netflix. I’ve always liked the Exede service but this 

time it survived the ‘Hurricane’ test. Keep up the good work, Exede, and thank 

you for being there when all else was in turmoil }:-)’’ 

Question 2. One issue this Committee has discussed at previous hearings is the 

issue of space debris. 

According to NASA, there are over 500,000 pieces of debris orbiting the earth. 

This debris ranges in size from non-functional satellites, to fragmented debris as 

small as specks of paint. This debris travels around the earth at speeds of up to 

17,500 miles per hour, roughly ten times faster than a bullet. At these speeds, even 

the tiniest bits of debris can cause damage, and windows on the Space Shuttle were 

replaced because of damage from tiny debris. With the increasing launches of microsatellites and decreasing launch costs it is now easier than ever to launch craft into 

low earth orbit, and the problem is likely to increase many times over. Do you believe that current processes and regulations in the United States are sufficient to 

mitigate the increase in space debris? How can we work to address this issue? 

Answer. ViaSat has several U.S. geostationary spacecraft authorizations for its 

current broadband space operations and has applied for a medium-Earth orbit system. ViaSat works with its satellite manufacturers and vendors to assess and design 

its spacecraft to limit the probability of accidental explosions, ensure safe flight operations during the service life of its satellites, and to facilitate appropriate postmission spacecraft disposal in order to preserve a safe space environment. ViaSat’s 

U.S. authorizations contain conditions to ensure that the highest orbital debris 

standards and best practices for space operations are designed into and maintained 

while operating the spacecraft. 

It is important that the United States remain a leader in the development and 

implementation of space debris best practices and mitigation. In fact, the development of safe flight practices and disposal procedures in the United States, led by 

NASA and DoD over the years, has encouraged other space faring nations and commercial operators to adopt similar procedures leading to an excellent safety track 

record, even though there have been a few unfortunate incidents over the years. 

Continuing to encourage industry best practices in partnership with government 

satellite operators, is the swiftest and most effective way to ensure that the latest 

techniques are incorporated into existing and future spacecraft and operations. It 

also requires government and commercial operators to timely share flight data and 

routinely cooperate on an operational level. 

144 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. MAGGIE HASSAN TO

STEPHEN SPENGLER

Question 1. With the recent hurricanes and tropical storms devastating Florida, 

Texas, and Puerto Rico, I’d like to talk a little bit about emergency preparedness. 

If things go according to plan with this industry, in a matter of years our planet 

will be covered with low-orbiting satellites providing broadband to every corner of 

the Earth. That comes with a major responsibility to bring people back on line after 

storms and disasters. How is the industry thinking about emergency preparedness, 

and backup power? Is having an all-of-the-above approach to connectivity that incorporates satellite, fixed, and mobile broadband a good idea to make sure we can rebuild after disasters? 

Answer. Hybrid networks and solutions are essential to disaster recovery. Due to 

the geographical challenges that many of our customers face around the world, fixed 

and mobile network operators are already integrating satellite into their networks 

to provide resiliency and redundancy should their terrestrial network be rendered 

inactive due the effects of a hurricane, flood, earthquake or more extreme natural 

or man made disasters. For example, given the broad scope of the connectivity challenges following Japan’s 2011 earthquake, Japan’s mobile network operators have 

turned to Intelsat to fully integrate our satellite network into their own. By doing 

so, they will have increased resiliency and redundancy in case of a natural disaster 

as well as have a way to extend their networks and bring much needed connectivity 

to communities in the more remote areas of the country. 

During the devastating Hurricane Season of 2017, Intelsat provided communications services using its Globalized Network and IntelsatOne Flex managed service, 

a customizable offering that aggregates space segment, the Intelsat Epic NG high 

throughput satellites and the IntelsatOne terrestrial network into a simplified, unified ecosystem to quickly deliver bandwidth where it was needed most. Intelsat’s 

support efforts began even before the first storm approached land, initiating disaster 

recovery and restoration plans for customers across the media, broadband and mobility sectors with operations established in the projected paths of the storms. In 

some cases, customers transitioned hub operations and relocated staff to Intelsat 

teleport locations, maintaining unimpaired operations throughout the storms. With 

broadcasters being significantly impacted by the flood in Houston, Intelsat’s Galaxy 

16 satellite was used to provide vital connectivity to re-establish services and ensure 

that critical news coverage reached residents and those outside the area. 

Intelsat, Liberty Global and Kymeta teamed up to provide critical connectivity to 

Puerto Rico, whose infrastructure suffered catastrophic damage due to Hurricane 

Maria. Three Kymeta-Intelsat enabled vehicles crisscrossed 29 remote towns from 

October through December 2017. The vehicles were equipped with Kymeta 

KyWayTM flat panel, beam-forming, electronically-steered terminals that leveraged 

Intelsat’s satellite connectivity. Despite the lack of any electrical power or cellular 

service, the low power-consuming terminals provided Internet access using the vehicles to power the communications system. 

Intelsat also worked with AT&T and Verizon to provide VSAT services to restore 

communications for enterprise customers. Intelsat’s Ku-band broadband service 

helped banks and pharmacies open for customers again as well as providing communications support for the Puerto Rican government and FEMA. 

These are just a few of the many examples of the importance of hybrid 

connectivity when it comes to disaster relief. By incorporating the reach, resiliency 

and redundancy of satellite technology into a fixed/mobile network, operators will 

harden their networks, help ensure that critical connectivity is available to assist 

with medical needs, recovery efforts and play a role in maintaining or rebooting a 

region’s wireless infrastructure so that people’s lives can return to normal. 

Question 2. One issue this Committee has discussed at previous hearings is the 

issue of space debris. 

According to NASA, there are over 500,000 pieces of debris orbiting the earth. 

This debris ranges in size from non-functional satellites, to fragmented debris as 

small as specks of paint. This debris travels around the earth at speeds of up to 

17,500 miles per hour, roughly ten times faster than a bullet. At these speeds, even 

the tiniest bits of debris can cause damage, and windows on the Space Shuttle were 

replaced because of damage from tiny debris. With the increasing launches of microsatellites and decreasing launch costs it is now easier than ever to launch craft into 

low earth orbit, and the problem is likely to increase many times over. Do you believe that current processes and regulations in the United States are sufficient to 

mitigate the increase in space debris? How can we work to address this issue? 

Answer. The potential for increased space debris is a concern for all operators. 

Intelsat is a founding member of the Space Data Association, a voluntary group 

145 

formed for the purpose of encouraging and enabling the sharing of satellite flight 

data for both commercial and government satellites. We have long held the belief 

that sharing data and complete transparency is essential to safe space operations. 

With new constellations in lower earth orbit (LEO) fast approaching, it is more critical than ever that we increase the level of data sharing and transparency among 

the international satellite operators. 

While non-geostationary constellations will operate at a lower altitude than 

Intelsat’s geostationary satellites, our satellites will still traverse those orbits during 

launch and orbit-raising to the geostationary orbit, so there is concern about debris 

potential even in those lower altitudes, particularly given the number of satellites 

required to cover the earth. In addition, many nanosats/cubesats are less agile and 

pose both navigational and Space Situational Awareness challenges (SSA). This is 

in contrast to geostrationary satellites which are more flexible and at the end of 

their maneuver life, our geostationary satellites are boosted to a graveyard altitude 

in accordance with FCC requirements—generally approximately 300 km above GEO. 

In our view, the keys to successful Space Situational Awareness are: accuracy, actionable data, transparency, reasonable regulation and cooperation. To achieve that, 

we recommend the following: 

• Regulation needs to be appropriate to support spaceflight safety, but not limit 

innovation. We need appropriate regulation as debris mitigation standards applied to a geosynchronous satellite may be different than those of a large constellation of nano-satellites in low-earth orbit with little room to maneuver. And 

with the FAA taking a leadership role in the regulatory arena, this could lead 

to a more rational international framework than exists today. 

• Actionable Data/Transparency. The industry needs need accurate, actionable 

data. As a result, there is a need for a technical capability to catalog the date, 

integrate the various formats and throw out the outliers. The growing data collection, exploitation and dissemination requirements far outpace the ability of 

cumbersome government acquisition processes to keep up. The commercial capabilities in this area are revolutionary, and several companies have offerings 

that would solve many of today’s issues and anticipate those of tomorrow. It is 

our understanding that the U.S. Government leadership is aware of these capabilities and seeks to take advantage of them. 

• Realistic covariance. This is currently missing from JSpOC and commercial capabilities could provide fill that void. 

• Systematic debris retrieval service. The same way people of come together to 

clean up the Everest base camp, government should come together to clean up 

space of all unwanted debris. 

The Geosynchronous orbit is the most valuable piece of real estate that we have 

in Space. It should be protected by all means. While we need the U.S. to lead, we 

also need an International solution. We need to encourage government action as a 

public service for all international satellite operators and recommend an international pilot program that addresses the points above. That way, every satellite operator and launch service provider will design and operate their assets in a manner 

consistent with preserving a safe space environment for future generations 

RESPONSE TO WRITTEN QUESTION SUBMITTED BY HON. CORY BOOKER TO

GREG WYLER

Question. Mr. Wyler, you suggested a possible Commission to deal with space debris issues. What do you think should be the goals of this Commission? 

Answer. Bridging the Digital Divide must include sustainable development and 

the responsible stewardship of space. Today there are almost no rules for space traffic. Companies and countries can fly satellites in almost any location or altitude 

without regard to what is already there. This has led to overlapping system designs 

which, if built, have a high risk of physical collision. Companies and countries can 

also design satellites focused on cost without regard to safety. Issues like re-entry 

casualty risk can be all but ignored, allowing companies to use lower cost materials 

which do not burn up on re-entry and will impact the ground. As constellations grow 

to thousands of satellites, the continuous re-entry and earth impact create significant potentially uncontrollable hazards. 

This is precisely why space debris and space traffic management are in need of 

U.S. leadership. The U.S., as the largest market for services, has an opportunity to 

create a set of rules which govern these important space debris issues. These rules 

would be welcome globally by many other concerned nations. 

146 

The FCC is trying to address space debris, but its current role is limited. The FCC 

regulates the use of satellite spectrum, rather than in-orbit collisions or re-entry 

casualty risk. Even if the FCC could take a more active role, many satellite types, 

such as those for imaging or sensing, will not even need FCC approval for their activities. 

This proposed Committee (whether under an existing Department, Committee, or 

Commission) should include a team with deep knowledge of these space debris and 

re-entry casualty issues and have the goals of: 

(1) Ensuring any space objects for which U.S. authorization is sought meet a minimum common-sense standard to prevent space debris, including: 

a. Safe altitude separation, 

b. Designing for demise to minimize re-entry casualty risk. 

c. Adequate positional knowledge and maneuvering capability, 

d. Prompt satellite disposal upon decommissioning, and 

(2) Providing leadership on the global issues of space debris and re-entry casualty 

risks. The Committee should seek the advice of and work with, the FAA, 

NASA, and other U.S. agencies and organizations to promote minimum safety 

standards for space traffic. 

(3) Supporting other agencies faced with space debris related issues and reviewing the impact of satellite licensing with respect to U.S. liability for space debris under the 1967 Outer Space Treaty. 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY MAGGIE HASSAN TO

GREG WYLER

Question 1. With the recent hurricanes and tropical storms devastating Florida, 

Texas, and Puerto Rico, I’d like to talk a little bit about emergency preparedness. 

If things go according to plan with this industry, in a matter of years our planet 

will be covered with low-orbiting satellites providing broadband to every corner of 

the Earth. That comes with a major responsibility to bring people back on line after 

storms and disasters. How is the industry thinking about emergency preparedness, 

and backup power? Is having an all-of-the-above approach to connectivity that incorporates satellite, fixed, and mobile broadband a good idea to make sure we can rebuild after disasters? 

Answer. Satellites are the most reliable method of communications. Until now, 

their use has been limited by their cost, the high latency leading to a poor quality 

of service, and the size/difficulty of installing the satellite receiving terminal. 

OneWeb has designed and manufactured a new generation of satellites which overcome these prior obstacles. OneWeb’s new terminals will be small, lightweight, and, 

most importantly, low-power. OneWeb’s terminals can run on batteries for short durations or be powered by a small solar panel for longer durations. 

OneWeb was designed to operate in the most economically challenged emerging 

markets. These markets similarly have limited to no local power available and few 

structures to permanently mount large heavy satellite equipment. This ‘‘work anywhere’’ capability also makes OneWeb’s terminals ideal for providing network 

connectivity during emergency situations. 

OneWeb’s mobile terminals will enable first responders and families to have continuous connectivity regardless of the local cellular coverage. The mobile terminals 

can be placed on a vehicle and will include a small cell and WiFi to connect devices 

to the Internet. These mobile terminals will facilitate 100 percent coverage of the 

United States, augmenting Firestone’s planned coverage. 

With regard to bringing people back online, OneWeb will produce easy-to-install 

terminals in high volume, much like any other consumer products. OneWeb will 

work with government and industry bodies to support adequate stocking and strategic placement of its terminals to support continued connectivity during terrestrial 

outages caused by emergencies or natural disaster events. 

Question 2. One issue this Committee has discussed at previous hearings is the 

issue of space debris. According to NASA, there are over 500,000 pieces of debris 

orbiting the Earth. This debris ranges in size from non-functional satellites, to fragmented debris as small as specks of paint. This debris travels around the Earth at 

speeds of up to 17,500 miles per hour, roughly ten times faster than a bullet. At 

these speeds, even the tiniest bits of debris can cause damage, and windows on the 

Space Shuttle were replaced because of damage from tiny debris. With the increasing launches of micro-satellites and decreasing launch costs it is now easier than 

147 

ever to launch craft into low Earth orbit, and the problem is likely to increase many 

times over. Do you believe that current processes and regulations in the United 

States are sufficient to mitigate the increase in space debris? How can we work to 

address this issue? 

Answer. As mentioned above, unfortunately, the current processes and regulations 

are insufficient to adequately address the risk of space debris. The last significant 

U.S. regulation on space debris is more than 20 years old. The international treaty 

called the Outer Space Act was adopted fifty years ago, in 1967, long before the advent of the commercial space industry. This has contributed to a dynamic in which 

satellite technology and networks have evolved far beyond the regulatory regime 

created to address space debris issues. While many countries acknowledge this reality and are currently drafting papers addressing this topic, the current environment presents a unique opportunity for the U.S. to assume a leadership position 

and drive standards of excellence and space stewardship worldwide. 

As you have correctly pointed out, debris generation is a serious issue and just 

a single impact can cause thousands of new debris fragments which will damage entire altitudes for thousands of years. These impact and re-entry casualty risks can 

be minimized if Congress creates a regulatory regime empowered to enact simple 

common-sense rules that would address critical issues, such as preventing overlapping constellations or the launching of satellites manufactured with lower grade materials that do not burn up during re-entry and will impact the ground. 

Today there are still many altitudes available for safe, separated operation, and 

there are many ways to design satellites so they burn up upon re-entry. However, 

without meaningful regulations to ensure best practices, companies and countries 

can launch virtually any space object with no minimum orbit separation from others 

and no minimum design requirements. 

Space is the proverbial Wild West. 

To properly tame this frontier, Congress should consider the formation of a Space 

Debris Committee as a central figure to spearhead the protection of our space ecosystem and ensure it is maintained as an accessible resource for generations to 

come. 

Æ