Consensus Seen on Grandfathering DBS Earth Stations When Protecting BSS Terminals

A variety of satellite companies agree with the FCC's tentative conclusion that existing direct broadcast satellite feeder link earth stations should be grandfathered on proposed rules to mitigate potential ground-path interference between those earth stations and broadcast satellite service (BSS) subscriber earth stations receiving signals in the same 17.3-17.7 GHz band. While there are few such DBS feeder link facilities, AT&T said in comments filed Wednesday in docket 06-123, "they play a critical role in the delivery of video programming to millions of viewers and must be able to continue operating as they were designed to do under the rules in force when they were licensed." AT&T, EchoStar and Dish Network jointly and SES Americom responded (see here and here) to an International Bureau public notice last month seeking updated comments on the proposed ground path interference rules (see 1510080043). SES said it continues to believe limited changes should be allowable at such DBS facilities without a loss of grandfather status. AT&T said DirecTV previously had backed creation of a "non-protection zone" around such grandfathered sites, but it now agrees with SES and EchoStar that such a buffer zone isn't needed as BSS operators starting service near an existing grandfathered site "should make their own determination as to where their potential subscribers would not be subject to excessive levels of interference from the existing site." AT&T bought DirecTV. There also was broad agreement from filers for requiring coordination between new DBS feeder link facilities and 17/24 GHz BSS providers. Instead of set limits on the siting of, shielding for or equivalent isotropically radiated power at such new facilities, the parties involved in coordination should decide that themselves, SES said. AT&T also said it changed its mind about requiring DBS operators to put new uplink facilities in low-population density areas because the coordination and shield requirements proposed mean such a requirement isn't needed. "Those DBS providers who elect to place new uplink facilities in an area not considered 'remote' or exceeding some population threshold will need to manage the (potentially more burdensome) coordination required," it said. SES said one area where it has changed its views since the FCC originally took comments on proposed rules in 2007 is that it now leans toward using 5 dB as a link performance margin when determining coordination zones, instead of a proposed 2 dB -- a figure SES called "too conservative ... not reflect[ing] realistic operational data."