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March 2005
Vol 5 Issue 1

Feature Article
FCC Grants Primary Status for Shipboard Earth Stations

Case Corner
The Wireless Home - Spectrum Management is Essential

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by David Meyer
Manager, Frequency Protection Services

FCC Grants Primary Status for Shipboard Earth Stations

After a decade of regulatory activity, the FCC issued a rulemaking in January significantly increasing the potential for interference into 6.1 GHz terrestrial microwave facilities. Baring changes from reconsideration filings, the FCC ruling implements co-primary sharing of the 5.925 – 6.425 GHz (6 GHz) band between mobile Earth Stations on Vessels (ESVs) and Fixed Point-to-Point microwave paths. This article summarizes the FCC’s rulemaking.

The issue of earth stations onboard ships increases the complexity of performing interference analyses with fixed microwave facilities, and developing procedural standards has been a controversial issue within industry associations for years. Listed below is a description of the regulatory activity since 1991.

Timeline of ESV Regulatory Activity

Primary ESV Requirements Covered by the Rulemaking

Co-Primary Regulatory Status with Fixed Microwave Services

C-Band ESV’s (3.7 – 4.2 GHz / 5.925 – 6.425) are granted co-primary status with all other users of the lower 6 GHz band. Because of their co-primary status, they are required to prior coordinate with existing fixed microwave users. After an ESV has been successfully coordinated along a ship route and at dock sites, future Fixed Service (FS) users will be required to coordinate with the ESV operator. In this band, interference will originate from the ESV transmitter, so FS operators planning a microwave path will have to evaluate the potential for interference from these shipboard systems. If a ship moving along its route is predicted to interfere, then the FS operator will have to use interference mitigation techniques or accept the interference. In the 3.7 – 4.2 GHz band, interference will originate from FS operators and the ESV operator must accept the interference.

Ku-Band ESVs are granted primary status in the 14.0 – 14.5 GHz transmit band and in the 11.7 – 12.2 GHz receive band. Since these bands are not shared with Fixed Services, prior coordination is not required for the ESVs. The remaining segment of the Ku receive band, 10.95 – 11.2 and 11.45 – 11.7 GHz, is shared with FS operators, and ESV operators must accept interference from the FS links.

Coordination Requirements for Use of C-Band

ESV operators are required to prior coordinate their planned usage of the 6 GHz uplink band with all potentially affected FS stations (on-shore and offshore). This coordination will follow the standard procedures defined in FCC Part 101.103 (d) with regard to notification and response. Data elements required for the ESV coordination are the same as for a fixed earth station, except for the addition of the contour points along the vessel’s route. The FCC set the minimum coordination distance for an ESV operation to 200 km from each on-shore or offshore FS facility. However, the FCC declined to set an interference objective. The FCC has relegated this task to the Industry. Comsearch is using the standard interference objective of –154 dBW/4kHz into FS receivers until a consensus is reached on an appropriate interference objective that considers the mobile nature of the ESV transmitter.

To ensure that technical information is readily available to all potentially affected parties, the coordination details will be maintained by and available from the frequency coordinator. After successful coordination with all affected FS operators, the coordination data will be included with the FCC application filing. The ESV operator can commence operation as soon as the coordination is placed on Public Notice. If any objections are received within 30 days of the Public Notice date, the ESV licensee must immediately cease operation until the issue is resolved.

Spectrum Usage Limitations

Understanding the long-term impact on FS operations, the FCC is limiting the amount of spectrum that ESV operators can coordinate and license in the 6 GHz band. Each ESV operator is limited to 72 MHz per coordination location (36 MHz maximum per satellite, using at most two satellites). In addition, ESV operators are limited to 180 MHz for all ESV operations in a given area. The 180 MHz limit is applied to the total amount of spectrum coordinated by all ESVs at any single point on a waterway or that impacts each individual FS link.

Ship Size Limitations (Examples) and Inland Waterways

ESV operators are limited to vessels of 300 gross tons or above. Many FS operators requested a higher minimum weight to reduce the number of potential ESVs, but the FCC elected to use spectrum limitations to minimize the impact on FS operators. Following are examples of potential vessels that would qualify for the ESV operation:

The FCC declined to place any geographical restrictions on the ESV operations, thereby allowing ESV operation in inland waterways and harbors. This will allow vessels to coordinate ESV operation anywhere in the United States where the waterway will handle a vessel 300 gross tons and above. As an example, shown below is a plot of 6 GHz microwave paths that may be impacted by ESV’s coordinated along routes into New Orleans and into the Mississippi River.

Tracking, 24-Hour Contact Requirements, Auto-Shutoff

Due to the FCC’s concern of the ESV impact on 6 GHz FS operations, ESV operators must document and maintain vessel tracking data for one year. At any particular time, this data must include the satellite, transmit frequencies, emission bandwidths, time of day, location (latitude and longitude), and the country of registry of each vessel. If interference occurs into FS systems, the FS operator can ask the ESV operator for this information and it must be provided to the FS licensee and the FCC within 24 hours. Consequently, each ESV must have a contact point in the United States available 24 hours a day, 7 days a week to provide the requested information. These contact points are required to be supplied to the FCC for posting on its website. In addition, the ESV operation is required to automatically shut off the transmitter if the vessel drops below coordinated speeds or strays outside the coordinated sea-lanes/waterways.

Precautions Microwave Licensees Should Take

As a co-primary user of the band, microwave licensees need to ensure that their paths are fully protected. Microwave operators should verify that their frequency coordinator is fully aware of the technical aspects of ESV operation and has the necessary tools to provide complete, accurate engineering analyses during the design process. Comsearch has been actively involved in industry forums to define the analysis procedures to evaluate ESV operations. We have developed software programs and coordination procedures to quickly review any ESV coordination and determine its impact on all protected terrestrial paths. Our Frequency Coordinators will analyze the impact of all ESV operations on new 6 GHz paths being coordinated. Microwave licensees need to be aware of this new interference source and the possibility that one of their 6 GHz microwave paths may encounter interference near the coast, a waterway, or harbor. In order to ensure that a path is protected, it is imperative that coordinated ESVs are carefully and accurately reviewed.

by Laura Fontaine
Director, Spectrum Management

The Wireless Home – Spectrum Management is Essential

Most people who attend a wireless trade show, like the one recently held by the Cellular Telecommunications and Internet Association (CTIA) in New Orleans, Louisiana, go with the intention of seeing and learning about the latest in cutting-edge wireless products. This year, attendees were treated to an impressive showcase of applications, products and services that make up the Wireless Dream Home. CTIA built a 7,000 square foot model home on the show floor to allow visitors to experience wireless home networking to its fullest.

The home included demonstrations from over 30 companies using unlicensed technologies such as WiFi, bluetooth, and Ultra Wide Band (UWB). The demonstrations included a Hummer vehicle with wireless traffic monitoring, a pet location device, a wireless home control (i.e. thermostat, lights, etc), an interactive crib, surveillance cameras accessible from a wireless phone, and more.

With so many wireless devices operating in close proximity to one another, and in some cases sharing the same spectrum, interference problems will occur. A proactive approach to spectrum management and frequency engineering is essential to effectively control and monitor this environment.

Recognizing the importance of spectrum management, the CTIA has selected Comsearch to serve as the spectrum manager for their two annual trade shows for the last eight years. This year, we took on the added task as spectrum integrator for the Wireless Home. We were tasked by the CTIA to coordinate and manage all exhibitor spectrum requirements and usage in the Wireless Home. Comsearch also provided on-site interference monitoring during the show to evaluate the radio frequency environment.

Spectrum management for this year’s Wireless Home was a multi-phased process that required engineering expertise as well as effective negotiation skills. The first phase of the process involved information gathering. Because of the diverse nature of technologies and devices within the home, it was necessary to gather information on all technical aspects of the demonstrations and devices, including operating frequencies, setup, location, and technology description. This information was used to perform a complete study of the home’s RF environment considering the interference potential to and from each wireless device in the home and on the show floor.

The next phase involved verifying that the devices would be compatible with one another. To do this, we considered distance separation within the home, the susceptibility of the device, as well as the frequency band.

The final phase is putting the plan into action. We paid particular attention to numerous demonstrations based upon WiFi or WiFi-like technologies, considering that there are a limited number of channels within the 2.4 GHz unlicensed band available for operation. We found it necessary to consolidate the WiFi demonstrations on a single network using three access points within the home. Each device was assigned to a specific channel. We maintained the greatest distance separation between devices using adjacent channels. We also utilized access points with directional antennas to limit the signal to specific areas of the home to reduce interference in those areas. A little spectrum horse-trading also helped to fix a few problems. In the end, these interference mitigation techniques allowed successful and simultaneous operation of all unlicensed devices within the home.

Industry organizations that host wireless conferences with equipment demonstrations should take proactive steps to address spectrum management issues. Inadequate spectrum planning can result in interference problems that substantially impact vendors’ equipment demonstrations, which no one wants. With the introduction of myriad new and existing wireless devices and technologies, the need for proactive spectrum management has become essential to ensure that all trade show participants enjoy the maximum benefit from their experience.

MICROWAVE

Avatar Environmental, LLC, Report Released Regarding Migratory Bird Collisions With Communications Towers - (DA No 04-3891, Dkt No 03-187) 
DA-04-3891A1.pdf

Rules Amended to Permit New Wideband Unlicensed Devices - The FCC acts to facilitate the introduction of new unlicensed wideband devices in the 6 GHz, 17 GHz and 24 GHz bands.  (Dkt No 98-153, FCC No 04-285)
Dkt-No-98-153.pdf  FCC-04-285A1.pdf  FCC-04-285A2.pdf

Increased Funding for Rural Telemedicine Services - The FCC expanded its program to bring up-to-date medical services and information to rural areas through telecommunications.  (Dkt No 02-60, FCC No 04-289)
Dkt-No-02-60.1.pdf Dkt-No-02-60.2.pdf   Dkt-No-02-60.3.pdf  Dkt-No-02-60.4.pdf Dkt-No-02-60.5.pdf  FCC-04-289A1.pdf  FCC-04-289A2.pdf  FCC-04-289A3.pdf  FCC-04-289A4.pdf  FCC-04-289A5.pdf

Deployment Of Broadband Communications On Vessels Promoted - Rules adopted to promote market-based deployment of broadband technologies. Established licensing and service rules for Earth Stations on Vessels operating in the 5925-6425 MHz/3700-4200 MHz (C-band) and 14.0-14.5 GHz/11.7-12.2 GHz (Ku-band) frequencies. (Dkt No 02-10, FCC No 04-286)
Dkt-No-02-10.1.pdf  Dkt-No-01-10.2.pdf  FCC-04-286A1.pdf FCC-04-286A2.pdf DOC-256000A1.pdf

Interference Report Concerning Garage Door Opener Controls Near Military Bases - (DA No 05-424) 
DA-05-424A1.pdf

Broadband PCS Spectrum Auction Closes, Raising Over $2 Billion -
DOC-256841A1.pdf

Access Opened to New Spectrum For Wireless Broadband In The 3650 MHz Band - The FCC adopted rules to open access to new spectrum for wireless broadband in the 3650-3700 MHz bands.  Adopted hybrid approach from both of the FCC's unlicensed and licensed regulatory models and provides for nationwide exclusive licensing. (Dkt No 98-237, 02-380, FCC No. 05-56)
FCC-05-56A1.pdf  FCC-05-56A2.pdf  FCC-05-56A3.pdf  FCC-05-56A4.pdf

811 Designated as Nationwide Contact Number - The FCC designated 811 as the Nationwide Number to Protect Pipelines, Utilities from Excavation Damage.  Contractors and others will call before conducting excavation activities. (Dkt No 92-105, FCC No 05-59) FCC-05-59A1.pdf  FCC-05-59A2.pdf

Rules Amended to Implement WRC-03 Decisions - Amended Parts 2, 25, 73, 90, and 97 of the Commission's Rules to implement allocation changes to the frequency range between 5900 kHz and 27.5 GHz in line with the World Radiocommunication Conference (Geneva). (Dkt No 04-139, FCC No 05-70)
FCC-05-70A1.pdf

Commissioner Martin Comments On Being Named Chairman of the FCC -
DOC-257451A1.pdf

SATELLITE

FCC holds Satellite Forum
The Federal Communications Commission (FCC) hosted its second annual Satellite Forum focusing on the role satellites play in everyday communications and how the lives of consumers in the United States and around the globe are enhanced by these services at its facility on March 21, 2005.

The forum was designed to educate and inform the public about the variety of satellite services available.  The event featured discussion panels and interactive demonstrations of satellite-based communications services. 

Four sessions highlighted the areas of mobility, integrated services, solutions meeting needs in developing countries, and portability.  The mobility session outlined satellite services that provide high-tech communication capabilities to consumers as they move, in trains, airplanes and automobiles.  The integrated services session showcased communications services that combine satellite and other technologies to serve consumers and businesses.  The global solution session discussed satellites providing instant infrastructure and disaster relief in the developing world. The portability session displayed and discussed new, cutting edge consumer devices deployed for satellite communications.      

More information can be found at http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-05-314A1.doc

FCC Permits ATC operation on MSS Systems
On February 10, 2005 the FCC revised the rules adopted in 2003 for flexibility in the provision of Mobile Satellite Service (MSS) communications, permitting the addition of ancillary terrestrial components (ATC) to MSS systems. This decision allows satellite operators to integrate ATC to existing MSS systems and modified the rules governing ATC to facilitate provision of improved services to U.S. consumers and public safety officials. The modified rules will give MSS operators more flexibility in designing and operating their networks, while continuing to provide other MSS operators protection from harmful interference. 

The order reaffirmed requirements that MSS operators must provide substantial, commercially available, sustainable MSS service over their entire geographic coverage areas, and must provide fully integrated MSS/ATC.

This changes the interference rules in the L-band (1525-1559 MHz and 1626.5-1650.5 MHz) to allow MSS/ATC operators more flexibility to design and implement their systems according to market need. In addition, it also clarified the licensing rules to allow pre-operational MSS licensees demonstrating that they will meet the gating criteria when they do deploy their satellites to simultaneously begin MSS and ATC services.

The FCC order can be found at: http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-05-30A1.doc

Aeronautical Mobile Satellite Service NPRM Technical & Service Rules
Commission Proposes Flexible use of Ku-Band frequencies to further facilitate provision of Broadband satellite services on airplanes. The proposed rule making addresses the regulatory framework for the licensing and operation of AMSS, and addresses the growing demand for two-way broadband data and communications capabilities onboard aircraft.

The Notice of Proposed Rulemaking, proposed by the Commission seeks a regulatory framework for licensing the operation of Aeronautical Mobile Satellite Service (AMSS) systems to communicate with fixed-satellite service (FSS) networks in the Ku-band frequencies.  AMSS potentially offers consumers the benefits of broadband services while traveling by air, both domestically and internationally.  Aircraft Earth stations (AESs) in the AMSS can be used to provide broadband telecommunications services to passengers and crew on commercial,  government, and executive/private aircraft.  The Notice responds to an emerging marketplace need by potentially permitting more flexible use of the Ku-band while protecting existing fixed terrestrial and satellite services from harmful interference.

Specifically, the Notice:

1. Examines frequency allocation issues in the Ku-band where AMSS systems will operate and seeks comments on procedures to protect space research service and radio astronomy service sites from AMSS operations in the band; 
2. Proposes rules and procedures to license AMSS networks that would permit blanket licensing of an AMSS network similar to the licensing rules for very small aperture terminals (VSATs) that currently operate in the Ku-band;
3. Seeks comment on the establishment of a regulatory framework that could enable foreign-licensed AES terminals to operate in United States airspace without causing harmful interference to domestic operations.

The FCC NPRM can be found at http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-05-14A1.doc

Procedures to Govern the Use of Satellite Earth Stations on Board Vessels
In this Report and Order, the FCC establishes licensing and service rules for Earth Stations on Vessels (ESVs) operating in the 5925-6425 MHz/3700-4200 MHz (C-band) and 14.0-14.5 GHz/11.7-12.2 GHz (Ku-band) frequencies.

The commission touts this action as promoting market-based deployment of broadband technologies to consumers traveling on the open seas and waterways in and around the United States and its territories. The order adopts licensing rules and operational requirements to authorize ESV operations in both the C- and Ku- bands.  This authority provides regulatory certainty to all licensees in these bands by elevating ESV operational status from temporary to licensed authority.  They acknowledge the unique character of ESVs as a primary application in the FSS with mobile capabilities, and require ESV operations to protect incumbent FS, FSS and a limited number of Government operations.  As such, the Report and Order permits operations in the C-band, while encouraging greater use of the Ku-band by affording Ku-band ESV licensees greater rights and fewer regulatory restrictions.  Finally, they recognize the international character of ESV networks and set forth a framework for U.S.- and foreign-licensed ESVs in conformance with both the Communications Act and international accords on ESV operations.

The Report and Order identifies the coordination methodology and public notice requirements for ESVs. The interference objectives, Spectrum and Satellite Limits are referenced in this order, as measures to protect terrestrial Fixed Service operation. ESV off axis EIRP limits and associated rules for pointing accuracy are also referenced to protect Fixed Satellite Service operators.  

The complete report and order can be found at: http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-286A1.doc

Commission Further Streamlines Satellite Earth Station Licensing
The Federal Communications Commission adopted, as part of its “Consent Agenda”, modified licensing rules that will streamline the review of non-routine earth station applications and speed the availability of broadband satellite services to consumers.  In two separate items, a Fifth Report & Order and a Sixth Report & Order/Third Further Notice of Proposed Rulemaking, the Commission adopted changes to the current Part 25 technical and processing rules and proposed further changes designed to reduce review time for non-routine earth station applications.  Non-routine earth stations, often used to provide satellite-based broadband internet access, are earth stations that have smaller antenna diameters or operate at higher power levels than those specified in Part 25 of the Commission’s rules. 

In the Fifth Report & Order (IB Docket No. 00-248) the Commission adopted two new streamlined procedures for case-by-case review of applications for smaller-than-routine earth stations:

1. Certification Procedure: Applicants can provide certifications of prior coordination with satellite operators that ensure that proposed stations will not cause unacceptable interference to their operations.
2. Power Reduction: Applicants can file applications and specify that they will operate at a lower enough power level to prevent interference.

The item also adopts similar certification procedures for proposed earth stations with higher-than-routine power. 

In the Sixth Report & Order, the Commission adopted additional technical rule changes, including updating the rules for Very Small Aperture Terminals (VSAT) networks using Code Division Multiple Access (CDMA), so that the requirements are consistent in different frequency bands.  The Third Further Notice proposed rules that would give earth station operators more flexibility to adjust their operations to meet market-place demands.

The new procedures and technical rules are designed to allow the Commission to more quickly review and act upon applications, and ultimately speed new broadband services to consumers.

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-257289A1.doc

Comsearch Vice President to present at NAB 2005
Join Tim Hardy at the Broadcast Technical Regulatory Issues Session – Tuesday, April 19th from 1:00 p.m. – 1:30 p.m. Mr. Hardy’s presentation, will discuss the prior coordination process in detail and the procedures used for proper frequency selection. Register for your exclusive VIP exhibits pass invitation for free admission to the NAB exhibit hall.

Comsearch Offers a Free Microwave Training Class
on April 25th & 26th, 2005
Contact us at customersupport@comsearch.com to sign up now for more information.

Comsearch To Hold a Free Educational Seminar on Managing Interference in the Hospital for Healthcare Professionals on April 12, 2005
We will cover wireless issues that affect interference in the hospital, how to develop a wireless policy, and how to perform hands-on measurements that will help you mitigate interference.

Comsearch Offers USGS NED Terrain, 1 Acr-Second Data in Several Formats Including DEM and Pathloss^TM
Developed by merging the highest-resolution, best-quality elevation data available across the United States in a seamless raster format, the USGS National Elevation Dataset (NED) provides national elevation data in a seamless format with a consistent datum, elevation unit and projection. Click here for more information on our GIS Products or contact us at customersupport@comsearch.com for a quote.

FCC selects Comsearch as a Database Manager for 71-95 GHz Spectrum
Comsearch’s role as a database manager will enable licensees to search for available spectrum in these bands and register their links, ensuring interference-free operation with commercial and Federal Government users. Licensees can register through Comsearch’s online link registration database at www.gigabitlink.com.

Comsearch to present at WINDPOWER 2005
Join Les Polisky in Denver for AWEA’s WINDPOWER 2005 annual conference on May 15-18, 2005. Mr. Polisky will be available to discuss his poster presentation, “Telecommunication Collocation Issues for Wind Energy Facility Development” at the reception on May 15th.
Click here for more information.

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