0 slide 0 preventing interference from earth station vessels national spectrum managers association...
TRANSCRIPT
1Slide 1
Preventing Interference fromEarth Station Vessels
National Spectrum Managers AssociationMay 19, 2004
Mitchell Lazarus | 703-812-0440 | [email protected]
2Slide 2
Introduction
ESVs seek to operate in several bands shared with the Fixed Service (FS): 3700-4200 MHz 5925-6425 MHz 11.7-12.2 GHz 14.0-14.5 GHz
The FS is concerned only about 5925-6425 MHz. Even there, the FS does not oppose ESVs if FS
operation is protected.
3Slide 3
FS is Entitled to Protection from ESVs Long-standing FCC policy: Incoming services must
protect incumbents. The FS is entitled to full interference protection from
ESVs at 5925-6425 MHz. ESV pleadings object to the FCC’s “overt bias toward
the FS” and ESVs’ quest for “fair and balanced rules” These statements misunderstand the FCC’s statutory
obligation. As the interfering latecomer, ESVs are subordinate to
the FS. Past ESV authorizations have included this condition.
4Slide 4
Fixed Service Use of C-Band
FS applications include: public safety communications coordinating railroad trains controlling natural gas and oil pipelines regulating the electric grid backhauling wireless telephone traffic
These links are constructed for 99.999% 99.9999% availability.
5Slide 5
Threat from ESVs
Transmit beams on ESVs threaten interference into coastal FS receivers.
The threat is exacerbated by: in-motion sources lack of terrain possible transmission from non-coordinated
regions.
6Slide 6
ESVs Claim “No Past Interference”
ESV assertions of “no demonstrated interference” must be disregarded.
Signals from an ESV are intermittent, transient, and hard to track down.
Identifying an ESV as the source of interference requires taking the FS link out of service for an extended period.
ESV providers have refused to give FS operators the information needed to link particular ESVs to particular interference events.
7Slide 7
Frequency Coordination Is Necessary But Not Sufficient
Frequency coordination of ESVs is fundamentally different from that for fixed earth stations.
Frequency coordination depends a precise knowledge of each facility’s location.
A moving source opens the risk of transmission from a non-coordinated location.
8Slide 8
Needed Protective Measures (1)
Bar ESV operation on C-Band within 300 km of the U.S. coastline.
OR . . .
9Slide 9
Needed Protective Measures (2)
1. Require frequency coordination; ESVs must suspend transmission on route segments where coordination failed.
2. Renew frequency coordination every six months.3. Require a GPS device to shut down the ESV in non-
coordinated waters.4. Give FS operators real-time access to ESV data and a
24/7 contact capable of shutting down ESV transmissions.
5. Limit ESV coordination as to bandwidth, satellites, azimuths, and elevations.
6. Limit ESV license terms to two years.7. Limit ESVs to ships of 5,000 gross tons or larger.
10Slide 10
Who Bears the Costs?
The FS acknowledges these measures will entail costs for ESVs and may limit service.
The costs and limitations result from the ESV industry decision to use congested C-band frequencies.
If ESVs do not protect the FS, the FS will incur costs and/or lose revenue. . . . which amounts to forced subsidy of ESVs by
the FS.
11Slide 11
Conclusion
The FCC should adopt the interference-prevention measures set out by the FS.
