Really Rocket Science

More detail via TR Daily (subscription):

At issue is a proposal from the Utilities Telecom Council and Winchester Cator LLC for a new secondary fixed service allocation in the band. They have asked the FCC to launch a rulemaking to establish a single, nationwide CII licensee, which would coordinate and manage new fixed services in the band. The coordinator would be tasked with resolving interference issues and to lease the band on a secondary basis for non-CII commercial operations.

In comments filed with the FCC Friday on the proposal (RM-11429), the Satellite Industry Association said the plan would cause “unacceptable and unresolving levels of interference both to existing and future satellite services and to the proposed new terrestrial service.” SIA disputed the UTC/Winchester claim that secondary fixed use of the band without creating harmful interference is possible, saying it relied on a “fundamentally flawed” analysis by RKF Engineering that assumed a “level of allowable interference that is inconsistent with the proposed secondary status.”

The report uses an interference allowance of 6% of the total noise on the grounds that it is used by International Telecommunication Union radio regulations, but that threshold applies to “co-primary operations, not to the secondary transmissions proposed here,” SIA said. For secondary users, the appropriate interference threshold, outlined in Recommendation ITU-R S.1432, provides that fixed satellite service links should be designed to allow for an “aggregate allowance of 1%,” SIA said. “This is far less interference than the 6% standard used as the basis of the RKF report’s analysis.”

SIA also said the proposal would impose “unacceptable coordination obligations on existing secondary users of the Ku-band.” For example, aeronautical mobile satellite services (AMSS) are currently classified as a secondary service, but the petition does not address how terrestrial transmitters would share the band with aeronautical earth stations, the satellite group said. “Any sort of coordination framework that placed restrictive obligations on the operation of AES would have severe effects on the service,” it said.

The Boeing Co. opposed the petition, citing its belief that the use of the spectrum envisioned by the UTC would cause “harmful interference” to existing satellite services in the band. The proposal to increase the noise floor by 6% would “cause a shutdown of Boeing’s AMSS network unless Boeing reduces its data rate,” the company said. Such data rate reductions would “quickly eliminate the utility of Boeing’s aeronautical broadband service, which is used by its government customers for high data rate services such as Internet access and video conferencing,” it said.

The National Spectrum Management Association raised a number of issues that it said needed “further clarification,” including how the envisioned single nationwide licensee/coordinator would “prioritize deployment and operation of CII networks over other new uses of the band or choose among more than one noncommercial or commercial entity that desires to use the band.” For example, the group wondered whether CII requirements would trump those of non-CII users in “cases where this would require disruption of an incumbent non-CII user with equivalent regulatory status.”

In addition to raising concerns about issues like interference, some commenters questioned the premise of the petition of promoting critical infrastructure protection. “Notwithstanding the petition’s rhetoric, the facts make clear that the proposal is motivated solely by commercial interests and that the planned fixed-service deployment cannot feasibly co-exist with ubiquitous FSS terminals deployed today, much less with continued development of new FSS applications and ubiquitous services,” said SES Americom, Inc., New Skies Satellites, Inc., and Intelsat Corp., in joint comments.

SES, New Skies, and Intelsat said there is “absolutely no evidence” that existing allocations are “insufficient to satisfy utilities’ needs,” adding that CII entities can obtain services from a “broad range of providers using a broad range of technologies.” They said it was “clear that the proposed new allocation is driven by Winchester’s desire to lease spectrum for profit, not to address any CII requirements.”

Qualcomm, Inc., opposed the petition, criticizing the proposal to enable CII entities to lease the spectrum to commercial terrestrial use on a “pre-emptible basis.” Such an arrangement would “make 500 MHz [megahertz] of spectrum available for commercial terrestrial use without an auction,” it said. “The petition proposes no Commission oversight of this arrangement and not a single regulation to ensure that the dominant use of the spectrum will actually be for CII.” Qualcomm added that the proposal includes no build-out rules, no regulations to govern lease terms, and “no Commission involvement of any kind.” The proposal “depends on a legal fiction that the CII use will be the ‘dominant’ use, but there are no safeguards proposed to ensure that this will be the case,” Qualcomm said. Qualcomm also asserted interference concerns, specifically to mobile terminals that use the 14.0-14.5 Ghz spectrum for earth-to-space transmissions and the 11.7-12.2 Ghz band to receive space-to-earth transmissions.

But UTC defended the petition, pointing to the need for utilities to have access to more spectrum, specifically to enable more “smart grid” applications. “Two-way communication between utilities, their substation, transformer, and line assets; their customers’ meters and appliances; and among utilities on a regional basis will generate huge amounts of data that utilities are already wondering how they will manage,” it said. “Much of this communication will be wireless; however, the critical infrastructure industries currently have no RF spectrum access to accommodate these needs.”

UTC also said the satellite industry’s concerns about interference are “unsubstantiated.” It said that “UTC and Winchester have provided detailed technical information showing that this band can be shared successfully, and have demonstrated CII entities' willingness to accept significant
restrictions on their operations, coordination procedures and a single point of contact to ensure that satellite operations do not experience harmful interference, or that any instances are resolved quickly.”

The Fixed Wireless Communications Coalition offered support for the petition, saying that fixed service spectrum is in “chronically short supply,” particularly in heavily populated areas, following the FCC’s reallocation of large amounts of fixed service bandwidth to other services. “The entire 2 GHz band, once the mainstay of long-haul fixed service microwave, is now allocated to PCS, AWS, and mobile satellite services,” the coalition said. Although many former uses of 2 GHz band spectrum have tried to relocate to the 4 GHz and 6 GHz bands, they have been blocked by satellite earth stations that are “routinely coordinated and licensed for the entire band and satellite arc.”

“The upper 6 GHz has no satellite blockage, but does have a bandwidth limitation of 10 MHz,” the coalition added. “Ongoing international negotiations threaten to impair fixed service operation at 10 MHz. New rules allowing smaller antennas in the 11 GHz band, while very welcome, will greatly increase usage over the next few years. There is little 18 GHz spectrum left for the fixed service, following reallocations to satellite operations.”

The coalition said the petition addressed protection issues in detail and demonstrated that the new service can be implemented without causing harmful interference. “UTC proposes that the new service be fully frequency coordinated as to all links - point-to-point and point-to-multipoint, fixed and temporary,” it said. “Knowing where the satellites are, the frequency coordinator can block the construction of any link that threatens harmful interference. If interference does occur, the frequency coordinator can serve as a single point of contact to quickly pinpoint the link responsible and shut it down.” - Brian Hammond, brian.hammond@wolterskluwer.com