By Christian Kuzdak
Freedom Technologies Inc. (FTI) is proud to present Spectrum Insights, a new series in which we share our thoughts on developing spectrum and telecommunications trends. The world of spectrum is a rich conversation among stakeholders, policy makers, technologists, academics, and analysts. FTI has been part of that conversation since 1992, and our experts are eager to share their perspective. In the series of blog posts below, FTI’s technology policy team seeks to explore some of the most fascinating and impactful developments in our corner of the world, inviting you to join the conversation.
Even as regulators grapple with the challenges of today, they cannot afford to be blind to the spectrum trends of tomorrow. Non-geostationary orbit (NGSO) satellite “constellations,” in-orbit servicing vehicles, and celestial exploration are just a few of the space-based activities that will require far more spectrum in the coming years. In this second installment in a three-part retrospective on 2022, we will dig in to the developing world of space spectrum, identifying major milestones from the past year.
Spectrum in Space
On November 16, 2022, the first crew-capable mission to the Moon in over 50 years launched from Kennedy Space Center in Florida. Artemis I, now having completed its return journey from the Moon, signaled NASA’s return to deep space exploration, and marked the beginning of efforts intended to establish a permanent human presence there. As NASA’s plans unfold, they will require access to various spectrum bands to support spacecraft going to and from the Moon as well as installations in lunar orbit and on the lunar surface. The 7/8 GHz band (7.125-8.500 MHz) in particular is critical for communications between Earth and planned objects on and around our Moon. Recent and repeated calls from industry representatives to focus repurposing efforts on this band could set up a protracted dispute should the band be selected for review by regulators or congress in the remaining days of the lame duck session.
But NASA is far from the only entity expanding operations in space. Numerous companies like SpaceX’s Starlink and Amazon’s Project Kuiper have made tremendous strides in 2022. These constellations promise connectivity in places terrestrial operators just won’t build, and with thousands of operational satellites in orbit, they are beginning to look like a viable business model. The existence of these constellations has given rise to new challenges for regulators, including at the FCC. With tens of thousands of planned objects in orbit, physical and spectral environments are bound to get crowded. That is why the FCC in September updated its orbital debris rules to require disposal of satellites within five years of mission completion. The move prompted criticism from House Science Committee leadership, which questioned the FCC’s jurisdiction; however, the Commission seems undeterred, signaling its intent to continue regulating space operations through the recent reorganization of its International Bureau into a new Space Bureau and separate International Office.
Simultaneously, the FCC released a forward-looking notice of inquiry (NOI) sourcing industry thoughts on in-space servicing, assembly, and manufacturing (ISAM) operations. ISAM is a cutting-edge, mostly theoretical, industry anticipating the needs of soon-to-be overwhelmed satellite operators. A suite of companies plans to survey, repair, refuel, and otherwise interact with active satellites, using complex maneuvers to rendezvous with and intercept objects in orbit. The benefits of a flourishing ISAM industry include orbital debris mitigation and removal, more sustainable satellite practices, and new, multi-orbit capabilities. The trick, of course, will be finding the spectrum for these unique craft. It is too early to say which bands might best serve them, but it is clear that the existing FCC rules are not designed to accommodate craft that regularly change orbits and rendezvous with multiple objects over the course of their mission.
Finally, we would be remiss not to mention what could be the next big spectrum hot topic at the FCC; namely, the 12 GHz band (12.2-12.7 MHz). Dish Network and SpaceX have spent the past year dropping dueling filings into the FCC’s docket on the band, arguing whether existing users can tolerate the introduction of new 5G terrestrial services. Incumbents like SpaceX say no, but studies from RS Access assert that sharing is viable, and in the public interest. Behind the scenes, FCC watchers have insisted that the Commission is poised to act on this band in an attempt to keep the so-called spectrum “pipeline” stocked with mid-band spectrum.
Broadly, the FCC seems to be positioning itself to play an increased role in space regulation at a time when the number of objects leaving the planet is increasing exponentially. As the National Space Council has pointed out, cooperation with other space players like NASA, NOAA, and the Office of Space Commerce will be critical to good governance, particularly as regulators address complex issues like spectrum rules, orbital debris, and astronomical visual interference. Continued guidance from the National Space Council may help clarify some of this complexity, particularly as regulators make their way through some of the most difficult new issues. Meanwhile, fights over the 12 GHz and 7/8 GHz bands are brewing as the FCC appears under pressure to accelerate 5G by supplying more spectrum to industry users. As both agencies face these difficult issues and attempt to balance federal equities with economic priorities in a newly developing space environment, observers will have the opportunity to view the progress of the FCC’s renewed relationship with NTIA, as discussed in our previous blog post.
The views and opinions expressed in this blog post are those of the writer and do not necessarily reflect the views or positions of any entities they represent.