IWG-3 DRAFT

**PRELIMINARY VIEWS ON WRC-03**

**WRC-2003 Agenda Item 1.19**: to consider regulatory provisions to
avoid misapplication of the non-GSO FSS single-entry limits in Article
S22 based on the results of ITU-R studies carried out in accordance with
Resolution 135 (WRC-2000);

**ISSUE**: Avoiding misapplication of non-GSO FSS single-entry limits
(e.g., through artificially splitting or combining of non-GSO FSS
systems).

**BACKGROUND**: WRC-2000 established single-entry equivalent power flux
density (epfd) limits for non-GSO FSS systems in certain frequency bands
in Article S22. The epfd limits are the sum of the power flux densities
produced at a GSO receive station by the emissions from all the transmit
stations within a non-GSO FSS system. The purpose of this item is to
conduct technical studies and to consider regulatory procedures in
accordance with Resolution 135 \[COM5/2\] (WRC-2000) to ensure that
there will not be any misapplication of limits in Tables S22-1 (epfd),
S22-2 (epfd) and S22-3 (epfd~is~) either by artificial splitting or by
combining of non-GSO systems.

> Misapplication of these limits, including artificial splitting or
> combining of non-GSO FSS systems, could:

a)  cause excess interference into GSO networks;

b)  reduce the number of non-GSO FSS systems that could be implemented
    > in an allocated frequency band;

c)  affect the regulatory requirements for a non-GSO FSS system in the
    > ITU coordination notification process; and

d)  affect non-GSO FSS systems that meet the single-entry limits in
    > Article S22.

Resolution 135 (WRC-2000) invites the ITU-R to conduct technical studies
and develop regulatory procedures, in time for consideration by
WRC-2003, to avoid misapplication of the single-entry limits included in
Tables S22-1, S22-2 and S22-3 of Article 22. This issue was also
identified in the CPM report of WRC-2000 in Section 3.1.2.4.10, where it
is noted that any misapplication of single-entry limits would invalidate
the entire basis of the derivation of these limits.

Further, Resolution 135 instructs the Director of the Radiocommunication
Bureau to review and, if appropriate, revise as of the end of WRC-2003,
any finding previously made in respect of compliance with the limits
contained in Article S22 for a non-GSO FSS system, for which
notification information has been received on or after 22 November 1997.
The Bureau's review and revision of findings is to be based on the
studies undertaken by the ITU-R pursuant to Resolution 135 after
WRC-2000.

**PRELIMINARY VIEW:**

1.  It is in the interest of all administrations to avoid any
    misapplication of the single-entry epfd limits. Misapplication could
    distort the regulatory or interference situation by violating the
    assumptions upon which the single-entry epfd limits were based and
    adversely impact the GSO FSS and BSS networks to be protected.

2.  Misapplication could artificially increase the number of non-GSO FSS
    systems, and thereby increase the interference to GSO networks over
    the levels agreed at WRC-2000; it could artificially reduce the
    number of competing non-GSO FSS systems by making coordination
    between non-GSO systems more difficult.

3.  The U.S. continues to participate in the studies within the ITU-R
    and is reviewing the need for the ITU-R to adopt regulatory
    procedures to avoid misapplication of the single-entry limits.

(04.12.01)