Ciel Satellite counters spectrum aggregation call from Telesat

Ciel Satellite LP has told Industry Canada that if it believes in the principle of aggregation of orbital spectrum licences with a single satellite operator, it should proceed to a public consultation on the issue. Below is an edited excerpt from comments submitted to an Industry Canada licensing process.The incumbent proposes a spectrum aggregation principle (SAP) that would have the effect of maximizing the number of frequency bands that are assigned to an operator at any given orbital location. The incumbent goes on to point out that nine of the 10 licences it is applying for are for satellites at orbital locations in which it already operates, the intended conclusion presumably being that the incumbent should be granted those licenses as a matter of government policy. Ciel notes the almost universal lack of commentary among the users for the SAP as a whole. Only one user, Canadian Satellite Radio Inc. (CSRI), a potential new entrant whose applications were deemed non-compliant, commented directly on the principle. The balance of the commenting users did not mention the SAP in their letters. The SAP should not be confused with the concept of assigning multiple frequency bands to a single operator on a case-by-case basis. Several commenting users did address the concept of potential efficiencies arising from a single operator utilizing hybrid satellites. Ciel does not disagree that there are efficiencies to be gained by encouraging the use of hybrid payloads. Indeed, many of Ciel's own proposals do just that (although Ciel wonders why the incumbent did not propose fulsome hybrid satellites at the DTH neighbourhoods if it truly believes in the efficient use of multiple frequency bands at an orbital location). However, it does not follow from this proposition that the department should therefore establish a presumptive right in favour of the incumbent in all spectra in every orbital position it now occupies, or occupies in the future. The larger SAP (which warns of operational difficulties which may arise when multiple operators occupy an orbital position) should be rejected by the department outright. Multiple operators flying at single orbital position is by any measure the norm in North America and elsewhere. The SAP makes absolutely no competitive sense and is not supported by the users. The department should continue with its existing practice of judging each proposed use (including hybrid proposals) on its own merits. If the department wishes to consider implementing a SAP in the future, Ciel expects that the department would follow its usual practice with respect to policy determinations of this kind and issue an industry-wide call for comments prior to implementation. Ciel acknowledges and agrees that the incumbent has enjoyed an extraordinarily strong position across every stage of the value chain in Canadian satellite services. Ciel, as well, has started to establish itself in the Canadian market as a credible alternative supplier of future satellite capacity and as seen from the comments of users, has also developed strong relationships and the respect of the Canadian satellite user community. Ciel urges the department to continue the development of a fully competitive marketplace. Ciel believes it has provided superior capacity plans for every contested slot, and that if licensed, the benefits to Canadian users and consumers would be far greater than the benefits proposed by the incumbent.

Ciel Satellite counters spectrum aggregation call from Telesat

News | January 26, 2007

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Ciel Satellite counters spectrum aggregation call from Telesat

News | January 26, 2007

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