- “Epfd adjustments could be explored in the Ka-band”
- “If the Commission is inclined to act unilaterally, then it should consider potential adjustments to the Ka-band epfd limits.”
- “[W]hen the Ka-band epfd limits are converted into I/N ratios, the results show that the upper Ka-band epfd downlink limits are more protective of GSO links than the ITU’s long-established, recommended I/N criteria for such links. As a result, Ka-band epfd limit adjustments might be possible without appreciable impact to existing GSO operations.”
- “EchoStar supports the Commission’s fresh look at the current sharing framework, is willing to acknowledge that further technical analysis is necessary to evaluate the appropriateness of the current epfd limits, and uniquely understands the need to modernize the rules under which NGSOs operate while preserving sufficient protection from harmful interference for GSOs.”
“The comments in this proceeding reflect broad support for revisiting the EPFD limits on NGSO systems in the Ku- and Ka-bands that were developed decades ago and were intended solely to protect GSO systems, without regard to the impact that overly restrictive limits have on NGSO systems.”
