Industry questions DOD guidance on SATCOM and hosted payloads
Kay Sears, president of Intelsat General, on industry concerns about DOD guidance on satellite communications and hosted payloads.
Kay Sears, president of Intelsat General, has spent more than 22 years working in satellite communications. In 2009, she was appointed to the president’s National Security Telecommunications Advisory Committee to provide information, technical expertise and advice regarding issues that may affect national security telecommunications capabilities. She recently spoke to Defense Systems Editor-in-Chief Barry Rosenberg.
DS: Toward the end of last year, the Defense Department released its guidance for obtaining military SATCOM services from a commercial provider via hosted payloads using military spectrum. I understand you have some issues with certain comments in the guidance. Can you please elaborate.
Sears: We think a policy on spectrum is important for the DOD because spectrum is really one of our most precious resources, and I think that as we work together—industry and government—there has to be some defined rules of the road when it comes to spectrum. The guidance that was issued by the DOD CIO’s office, however, was a little protectionist in my opinion. I think that in trying to protect their own spectrum they unnecessarily created barriers to working with the commercial operators at a critical time.
And the reason that I feel as though there were barriers created is because the guidance does not take into account the way that a commercial company might operate its satellites, and particular terms and conditions that might be negotiated in a hosted payload deal. So I believe that the guidance was created in somewhat of a vacuum. There were critical discussions that did not take place from government to government before the guidance was issued, and there was no discussion between the government and commercial providers before the guidance was issued. That potentially creates a narrow view of an issue that actually has a lot of complexities.
DS: Why do you consider the guidance protectionist?
Sears: I think the DOD CIO is concerned about protecting the spectrum that has been set aside for military and government use. And, quite frankly, we agree on the spectrum that is set aside for military and government use. There’s also spectrum that’s set aside for commercial use. What we would have liked to have seen, though, is a dialogue that goes farther than just protecting the government spectrum, but actually gets into ‘how do we actually work together to leverage the spectrum that we have?’ This guidance almost portends that the commercial industry is the adversary (versus who the real adversary is), and doesn’t address where we might be able to use both commercial and military spectrum together to increase the competitiveness of the U.S. in this very challenging environment.
DS: Who is the real adversary?
Sears: When it comes to determining how we are going to use spectrum for military communications the adversary is whomever we might be fighting, for example. This directive portends that the commercial industry is the adversary. We are not the adversary. Quite the opposite, the kinds of things that we are trying to do would be for the benefit of the U.S. military.
DS: What would you have said to the DOD regarding the guidance if you had been given the opportunity?
Sears: I would have brought up the fact that we should be leaving the door open to the leveraging of both commercial and military spectrum. Setting certain terms and conditions in a guidance letter essentially cuts that off.
The second thing I would have said is that there are specific things that an operator has to do to manage its own fleet that should be left up to the negotiation of a hosted payload deal. So it doesn’t allow for flexibility when [the DOD] sets the terms and conditions in the hosted payload deal. Each organization that wants to purchase a hosted payload, or work with commercial industry on a hosted payload opportunity, should have the flexibility to negotiate those terms. And I think the policy guidance went too far in trying to dictate what those terms are when, in fact, they should be part of a natural progression of writing a contract.
DS: The recently awarded Future COMSATCOM Services Acquisition (FCSA) satellite bandwidth contract is geared to results and the reliability of the network, as opposed to just providing a service. That will require a different way of thinking on the part of bandwidth providers. What are your thoughts on that?
Sears: I do think, for the majority of government and military [users], in particular, the different way of thinking would be that you don’t really dictate the solution; you dictate the requirement in these performance-based contracts.
DS: Don’t tell me how you want me to do it, tell me what you want done?
Sears: Exactly. That leaves the commercial industry to develop solutions and create differentiators within their own infrastructure. I also think as part of that (and we learned this through some of our performance-based contracts), there needs to be very clear demarcation points in that service. Where does the service begin and where does the service end? And exactly how are you going to measure the various components of that service? You can’t just break it up and measure one component at a time. You now have to measure all of the components across the service, and that’s a lot harder done than it is said. Clear demarcation points are needed because when you hand off to the government, you are riding on its network, versus something that’s part of your performance contract.
DS: It will be especially important to measure exactly what is being delivered to the government.
Sears: There are some great tools available now that, for example, can be placed at the modem end of the service to measure throughput and error rates. There are many good tools in the IP environment where we can provide good visibility into a network without the government actually owning the network. This gives them [government officials] comfort that they can rely on industry to provide them an end-to-end service, as well as a portal that lets them see real-time information on the availability and the throughput of what they’re paying for.
I do believe industry can deliver that, and I think it helps with the military’s transition from having to own and run the network to having visibility into it so it doesn’t have to own or run it.