Support and Opposition From Stakeholders
Subsequent to Qualcomm's FCC filing, several firms wrote the Commission to support or object to the proposal. Those in favor include , which operates a fleet of 563 Gogo-equipped aircraft and is in the process of outfitting 255 regional aircraft with the Gogo system.
“Delta's customers have come to expect access to the Internet on every domestic flight . . . demand for inflight access to the Internet is growing steadily . . . U.S. airlines will soon look for additional capacity alternatives to satellite-based systems that suffer from high latency and high costs,” attorney Alan Tilles wrote to the FCC on behalf of the Atlanta-based air carrier.
' letter to the FCC on the topic was equally supportive, saying the carrier “agrees with the central premise of the (Qualcomm) petition that U.S. travelers increasingly want and need broadband access while they are in flight.” Gogo service is available on several AA jetliners flying above the continental U.S. In late 2011, American started equipping the premium sections of its passenger cabins with Samsung Galaxy tablet computers to provide first- and business-class passengers with access to entertainment, social networking and cloud computing business services.
supports Qualcomm's petition. In his letter to the FCC, Chris Benich, vice president of aerospace regulatory affairs, agreed that U.S. air travelers “increasingly want and need to have broadband access while they are in flight.” Benich noted that Honeywell has a “long legacy” of providing L-band and Ku-band satellite communications systems for aircraft, and manufactured most of the 800-MHz Gogo avionics used by airlines. He wrote that the Ku-band air-to-ground system “will successfully coexist with existing satellite communications in the 14.0- to 14.5-GHz band. . . .”
Even Gogo came out in favor of the Qualcomm proposal, and told the FCC that its position, “as a market leading provider of air-ground communications” made it “particularly qualified to comment on the need for additional air-ground spectrum.” More than 2,100 commercial and business aircraft are equipped with Gogo air-to-ground broadband systems.
Ku-band satellite service providers and the Satellite Industry Association (), a trade association representing them, are not so sanguine. “(Qualcomm's) petition does not adequately address serious interference concerns between co-frequency operations or establish how the secondary ATG [air-to-ground] service could practicably coexist with primary [satellite] operations in the 14.0- to 14.5-MHz band,” SIA president Patricia Cooper wrote in a September 2011 letter to the FCC. Specifically, the SIA is concerned that Qualcomm's theoretical maximum permissible 6% Ku-band NGSO satellite interference level is too high. The SIA also believes that Qualcomm's 1% interference level with GSO satellites “is cause for concern.”
However, Jalali subsequently addressed those issues with SIA officials and he believes they have been defused. He reiterates that Qualcomm wants to protect Ku-band satellite communications because the firm's OmniTRACS vehicle tracking system depends on it. The handoff process for aircraft transiting between adjacent cells, for instance, uses “the least amount of transmit power” to attain a satisfactory carrier-to-noise ratio and a Ku-band satellite interference level “well below 1% in all scenarios.”
also objects on the grounds that the system “could significantly impact” Ku-band satellite signals and that interference “may be significantly worse than that assumed in the petition.” However, Qualcomm's proposed performance specifications for the system put a cap on the total permissible signal interference generated by all system users rather than just specifying standards for individual radios.
Most of the Ku-band satellite broadband providers' objections appear to be economic rather than technical. As an example, the SIA's Cooper writes “ . . . there is no demonstrated public interest need to commence a complex and extended rulemaking proceeding for a new ATG service when existing and planned terrestrial and satellite-based systems already meet current and expected demand for ATG communications to support inflight passenger connectivity.” Such a statement suggests that Ku-band satellite broadband services providers are more concerned that competition from the Qualcomm system may hurt sales rather than signals.
Perhaps the most-important economic challenges come from Alcatel-Lucent, the global telecommunications company headquartered in Paris. That firm's September 2011 letter to the FCC appears to suggest that the fair market cost of an FCC spectrum license for a huge 500-MHz swath of Ku-band would make such a system cost-prohibitive if its only consumers were the 400,000 to 500,000 airplane passengers, suggests Jeffrey Marks, the firm's senior counsel and director of regulatory affairs.
“The value of terrestrial spectrum is much higher than for air-to-ground,” wrote Marks. He pointed out that Gogo (nee Aircell) won a bid for a 3-MHz spectrum for its ATG system by offering only $30 million. In contrast, terrestrial mobile broadband operators pay “billions for nationwide licenses” because the U.S. population is close to 309 million, more than 600 times the peak number of air passengers. He noted that air passengers may be willing to pay a premium for broadband access in flight, but it would be “difficult for a prospective air-to-ground operator to justify paying a competitive price for spectrum in an auction with terrestrial operators.”
Alternatively, Marks believes that other and narrower slices of spectrum ought to be considered for an air-to-ground system. Alcatel-Lucent, for instance, is leading an effort to adapt terrestrial cell phone broadband systems to aircraft and it's working closely with the European Conference of Postal and Telecommunications Administrations (CEPT) to achieve that goal. Alcatel-Lucent also believes the aviation community ought to work toward a common standard for air-to-ground broadband systems, one that would harmonize FCC standards with the CEPT's regulations for an advanced air-to-ground system.
Jalali, though, believes there are no “showstoppers,” based upon his communications with the FCC, SIA and other stakeholders. Indeed, he believes such a system could win FCC approval in as little as 24 months, but he cautions against second-guessing the rulemaking process, especially for such a large chunk of bandwidth.
Even if Qualcomm succeeds, though, its Ku-band system may need to grow by an order of magnitude to meet demand by the time it reaches the market. It's currently designed to handle 600 aircraft, but there are more than 5,000 aircraft in the air over the U.S. every day, each carrying an average of up to 100 passengers.
Fortunately for those 500,000 air travelers, Ku-band and Ka-band satellite broadband will provide additional, albeit perhaps more expensive, access to the Internet than the proposed system. With the explosive growth in mobile broadband traffic, the demand for high-speed Wi-Fi in the air will support many satellite- and ground-based broadband networks. And those developments finally will unleash the full potential of the airborne office. BCA