Mr. Donald Abelson

Chief of the International Bureau

Federal Communications Commission

445 12th Street SW

Washington, D.C. 20554

Dear Mr. Abelson:

The National Telecommunications and Information Administration (NTIA),
on behalf of the Executive Branch Agencies, has approved the release of
an additional Executive Branch proposal for WRC-07. This proposal
considers the federal agency inputs toward the development of the U.S.
Proposals for WRC-07.

The enclosed document contains a draft U.S. proposal for agenda item
1.13. This proposal is forwarded for your consideration and review by
your WRC-07 Advisory Committee.

Jim Vorhies of my staff is the primary contact for NTIA.

> Sincerely,
>
> (*Original Signed 5 August 2005*)
>
> Fredrick R. Wentland
>
> Associate Administrator
>
> Office of Spectrum Management

Enclosure

United States of America

## DRAFT PROPOSAL FOR THE WORK OF THE CONFERENCE

**Agenda Item 1.13:** taking into account Resolutions **729 (WRC-97),
351 (WRC-03)** and **544 (WRC-03)**, to review the allocations to all
services in the HF bands between 4 MHz and 10 MHz, excluding those
allocations to services in the frequency range 7 000-7 200 kHz and those
bands whose allotment plans are in Appendices **25, 26** and **27** and
whose channeling arrangements are in techniques and the spectrum
requirements for HF broadcasting;

**Background Information:** This is a very broad agenda item, as there
are multiple services allocated to the HF bands between 4 MHz and 10
MHz, including aeronautical mobile (OR), aeronautical mobile (R),
amateur, broadcasting, fixed, maritime mobile and mobile services.
Agenda item 1.13 covers three resolutions that deal with three separate
issues. These issues are connected within the agenda item on the basis
that they cover overlapping frequency ranges. The CPM convened following
WRC-03 assigned the primary responsibilities for the separate issues to
different working parties.

***Resolution 351***:

> resolves
>
> "1) that, in order to provide full worldwide interoperability of
> equipment on ships, there should be one technology, or more than one
> interoperable worldwide technology, implemented under Appendix **17**;
>
> 2\) that, as soon as the ITU-R studies are completed, a future
> competent conference should consider necessary changes to Appendix
> **17** to enable the use of new technology by the MMS;"

The focus of Resolution **351 (WRC-03)** is to identify a digital
technology, or family of digital technologies, that provide
interoperability and improved usage of the MF and HF bands allocated to
the maritime mobile service under Appendix **17**. The scope of this
portion of the agenda item includes a review of all Appendix **17**
assignments to facilitate the introduction of these advanced maritime
mobile digital systems.

Resolution **351** **(WRC-03)** calls for studies to include; future
requirements of the MMS, technical characteristics of the digital
systems, the necessary modifications to Appendix **17** to enable the
use of new technologies by MMS, a timetable for the introduction of new
digital technologies, and recommendations on how digital technologies
can be introduced while ensuring compliance with distress and safety
requirements. In accordance with *resolves* 2 of Resolution **351**, as
soon as the ITU‑R studies are completed, a competent conference should
consider necessary changes to Appendix **17**, to enable the use of new
digital maritime technologies by the MMS. These studies are still
underway and should be refined to examine the requirements of GMDSS
electronic messaging.

The future spectrum needs of the maritime mobile service in the HF bands
are closely related to the introduction of new data exchange
technologies into the maritime mobile service, as an alternative
standard for narrow-band direct printing (NBDP). The use of NDBP is in
rapid decline for commercial communications. IMO has noted NBDP is
currently used for broadcasting of MSI, ship reporting, weather
forecasts and for business communications, e.g., by fishing fleets.
However, all these functions could in principle be provided by
alternative HF data communications technology. A PDNR for the new MMS HF
data exchange service has been developed based on commercial Orthogonal
Frequency Division Modulation (OFDM) (see 8B/135).

NBDP remains useful for providing distress communications in the polar
regions (sea area A4) when other terrestrial means of communication are
no longer reliable because of atmospheric noise, and there is no
coverage from geostationary satellite networks providing service to the
maritime community. This NBDP functionality will be preserved using the
HF distress and safety frequencies relocated to Appendix **15**.

Because the studies on this issue are continuing, a revision of
Resolution **351** to recognize the current views of the IMO regarding
the technology transition, to note the transition that has already taken
place, and to direct additional studies regarding the spectrum needed
for new technologies is appropriate.

***Resolution 544:***

> resolves to invite ITU-R
>
> "1 to carry out studies on this matter, particularly in respect of the
> bands identified in *noting* above, taking into account technical,
> operational, economic and other relevant factors, including the
> appropriate transitional arrangements, and how the introduction of
> digital emissions will affect the HF broadcasting requirements and how
> such reallocations will affect other services using these bands."
>
> further resolves
>
> \"to recommend a future competent conference to conclude, where
> appropriate, on additional spectrum requirements for the broadcasting
> service, taking into account the interest of all affected services\"

Resolution **544 (WRC-03)** resulted from work that was not completed at
WRC-03. WRC-03 allocated 50 kHz in Region 2 to the broadcasting service
as a result of the realignment of portions of the 7 MHz band under
WRC-03 agenda item 1.23. Prior to WRC-03, the broadcasters identified a
shortfall in the 4-10 MHz band of 250 kHz of spectrum to alleviate
co-channel interference, and 800 kHz of spectrum to alleviate adjacent
channel interference. The Resolution also calls for a review of the
impact of relocating other services from current spectrum allocations if
these broadcasting spectrum requirements were accommodated as well as
what transitional arrangements should be made.

WARC-92 (**5.136**) decided to allocate 100 kHz of spectrum to the
broadcasting service which will transition from fixed and mobile service
allocations in 2007. Any further decrease in available spectrum may
affect the ability of fixed and mobile services users to establish and
maintain reliable essential and emergency communications services. Any
consideration by WRC‑07 of reallocating additional spectrum to the
broadcast service should carefully consider the impact on existing and
planned fixed and mobile services. Currently, there are 2 102 kHz
between 4 and 10 MHz allocated to support the land mobile services and 2
712 kHz allocated to the fixed service. After April 1, 2007,
implementation of the results of WARC-92 reduces that amount to 2002 kHz
for land mobile and 2512 kHz for the fixed service as a result of the
reallocation to the broadcast service. After March 29, 2009, in Region 2
an additional 50 kHz is allocated from the fixed and land mobile
services to the broadcast service.

Because of their reliability and low cost, fixed and mobile HF services
will continue to be required by Administrations. Administrations must be
ready to support fluctuations in demand by the fixed and mobile service
during emergency communications. The fixed and mobile services are
unique in that requirements to use them increase during emergency
situations. Public Protection and Disaster Relief operations depend on
the availability of spectrum to support operations.

Displacement of current frequencies from the fixed and mobile service
may require considerable expenses for realignment of communication
networks and change (replacement) of antennas. In some cases it may be
hard to establish required radio links based on the loss of currently
available portions of the spectrum and also due to spectrum crowding
from realignment of assignments to account for any spectrum allocated
from the fixed and mobile service to the broadcasting service.

The operational databases maintained by the HF Coordinating Committee
illustrate that a broadcast primary allocation of 250 kHz of spectrum
would alleviate co-channel interference, and 800 kHz of spectrum would
alleviate adjacent channel interference. According to text contained in
WP-8A/199, which originated from WP-6E, the broadcasters currently
address this shortfall by using FS and LMS bands on a non-interference
basis under Article **4.4**. According to WP 6E/162, 80-85% of shortwave
broadcasting hours in the 4-10 MHz band operate within broadcasting
allocations and do not operate under Article **4.4**.

There are interference risks associated with Article **4.4** operation.
The HF Coordinating Committee and Administrations need to take these
risks into account when assessing cross border interference potential
and coordinating usage under Article **4.4**. Some Administrations have
reported interference from the broadcast service in the fixed and mobile
bands. At least one incident resulted in discontinuation of broadcaster
operations. Given this interference risk, Article **4.4** operations do
not represent successful broadcaster occupancy of the fixed and mobile
bands, nor do they justify reallocation of these portions of the fixed
and mobile bands to the broadcasting service.

Broadcast providers are currently investing in alternate delivery
methods which may be used to augment or replace programming hours. FM,
cable, satellite, and Internet are beginning to provide alternate
delivery in developed countries, but are problematic for developing
countries due to cost, coverage, and reliability.

Recent natural disasters have demonstrated that the fixed and mobile
services are unique in comparison to the broadcast service in that
requirements are driven up rapidly during the development of emergency
situations. Increased congestion is inevitable during periods of peak
usage by the fixed and mobile services.

WP 9C has noted that during the 2004-2005 Indian Ocean Tsunami Relief
Effort, the emergent need for HF communications drove up spectrum demand
rapidly. Because of existing extensive usage of the HF bands in the
disaster areas, it was not possible to provide all the required channels
to meet required emergency communications.

Ionospheric (skywave) signal propagation is frequency selective and
frequencies usable for communications between any two points change over
time throughout the day. This is why several different segments of
spectrum within the HF frequency range, are allocated to each radio
service. This enables the users of the service to have full time access
to frequencies that are usable throughout a 24-hour period.

For the fixed and mobile services, propagation concerns make it
essential that the frequency channels or sub-bands of an HF pool are
evenly spaced in order to adapt to the daily and seasonal changes in the
ionosphere. Concentration of spectrum in large blocks with large gaps
between them cannot be optimal based on HF propagation phenomena. Thus
band spacing and availability have become crucial factors which affect
all services and have the potential to multiply requests for additional
spectrum.

The fixed and mobile services transmit frequencies may change often,
spreading the traffic over a wider spectrum. Statistically this may make
it appear like there is lower occupancy of the HF spectrum. An adaptive
system may find better propagation conditions and establish a link with
lower power levels than non-adaptive systems. Given this agility, HF
stations or HF circuits kept in a silent mode or on watch must be
furnished with the full set of frequencies to meet emergency
requirements at any moment in time.

The impact to the fixed and mobile services of allocating additional
spectrum to the broadcasters would be too severe, since those additional
allocations would come from bands assigned to these services. This
situation will not change in the foreseeable future. Consequently
Resolution **544** should be suppressed.

***Resolution 729:***

> resolves
>
> "1 that, in authorizing the operation of frequency adaptive systems in
> the MF and HF bands, administrations shall:
>
> 1.1 make assignments in the bands allocated to the fixed and mobile
> services;
>
> 1.2 not make assignments in the bands:
>
> \- allocated exclusively to the maritime or aeronautical mobile (R)
> services;
>
> \- shared on a co-primary basis with the broadcasting service,
> radiodetermination service or the amateur services;
>
> \- allocated to radio astronomy;
>
> 1.3 avoid use which may affect frequency assignments involving safety
> services made in accordance with Nos. **5.155**, **5.155A** and
> **5.155B**;
>
> 1.4 take into account any footnotes applicable to the proposed bands
> and the implications regarding compatibility;
>
> 2 that frequency adaptive systems shall automatically limit
> simultaneous use of frequencies to the minimum necessary for
> communication requirements;
>
> 3 that, with a view to avoiding harmful interference, the system
> should evaluate the channel occupancy prior to and during operation;
>
> 4 that frequency adaptive systems shall be notified to the Bureau in
> accordance with the provisions of Article **11**,"

Resolution **729 (WRC-97)** deals with implementation of adaptive HF
systems and was not successfully addressed at either WRC-2000 or
WRC-2003. Adaptive HF systems are systems that monitor the propagation
environment on pre-established channels, and react to use the optimal
frequencies available for transmission.

Frequency adaptive systems automatically limit simultaneous use of
frequencies to the minimum necessary for communication requirements.
According to 6E/223, which originated from WP-9C, this characteristic of
adaptive systems does not necessarily reduce the number of frequencies
that must be made available to ensure successful link establishment.
Consideration must also be given to maintain quality of service for uses
that fluctuate in response to situations such as those that arise during
Public Protection and Disaster Relief. The number of frequencies in an
adaptive frequency pool is directly interrelated to the specific HF
propagation characteristics based on time of day, season, sunspot
activity, etc. Therefore, efficiency improves as more frequencies are
available. A network of stations is assigned a number of frequencies
over which to communicate, and each station is assigned a unique address
(*e.g.,* alpha-numeric).

Adaptive HF systems have been in use for over 20 years. No special
consideration in the ITU Radio Regulations is required to fully
implement adaptive HF systems. By their nature these systems already
automatically limit simultaneous use of frequencies to the minimum
necessary for communication requirements. These systems also
automatically avoid harmful interference by evaluating the channel
occupancy prior to and during operations.

To fully exploit modern HF technology, the availability of sufficient
and coordinated spectrum resources is crucial, and bandwidth beyond the
typical 3 kHz-channels must be available.

The channel bonding approach currently in use is based on the use of
several 3 kHz contiguous channels. The advent of HF 64 kbps modems has
begun to provide the ability to utilize HF spectrum for Internet, large
file transfer, and advanced electronic messaging. Loss of HF spectrum
allocated to the fixed and mobile services would constrain the
development of advanced technologies such as messaging, file transfer,
and the Internet.

The required studies related to adaptive HF technology have been
adequately answered. Therefore, Resolution **729** can be suppressed.

However, there is an emergence of high bandwidth requirements in the
form of advanced fixed and mobile HF systems which does require urgent
study. Therefore a new resolution is required to examine the issues
involved in implementing advanced fixed and mobile HF systems in the in
MF/HF bands.

**Proposal:**

**USA/ /1 MOD**

RESOLUTION 351 (WRC-07)

Review of the frequency and channel arrangements in the MF and\
HF bands allocated to the maritime mobile service with a view to\
improving efficiency by considering the use of new digital\
technology by the maritime mobile service

The World Radiocommunication Conference (Geneva, 2007),

**Reasons**: Editorial

considering

*a)* that the agenda of this Conference included consideration of the
use of new digital technology in the maritime mobile service (MMS) in
the MF and HF bands;

*b)* that the introduction of new digital technology in the MMS shall
not disrupt the distress and safety communications in the MF and HF
bands including those established by the International Convention for
the Safety of Life at Sea (SOLAS), 1974, as amended;

*c)* that changes made in Appendix **17** should not prejudice the
future use of these frequencies or the capabilities of systems or new
applications required for use by the MMS;

*d)* that the need to use new digital technologies in the MMS is growing
rapidly;

*e)* that the use of new digital technology on HF and MF frequencies
allocated to the MMS will make it possible to better respond to the
emerging demand for new services;

*f)* that the HF bands allocated to the MMS for A1A Morse telegraphy and
narrow-band direct-printing are significantly under-utilized at present;

**USA/ /2 MOD**

*g)* that the IMO supports replacing general communication
narrow-band-direct-printing with new HF data exchange technology capable
of working FEC NBDP,

*h)* that the IMO supports the frequencies of Appendix **15,**
concerning NBDP, be retained for the foreseeable future.

*i)* that the ITU Radiocommunication Sector is conducting ongoing
studies to improve the efficient use of these bands,

noting

a\) that different digital technologies have already been developed and
are in use in the MF and HF bands in several radiocommunication
services,

b\) that new maritime HF data transfer protocols have already been
developed to replace general narrow-band-direct-printing communications
using Appendix **17** frequencies,

noting also

that this conference has modified Appendix **17** to permit the use of
various channels or bands identified in the MF and HF bands for the
introduction of new digital technology,

resolves

1 that, in order to provide full worldwide interoperability of equipment
on ships, there should be one technology, or more than one interoperable
worldwide technology, implemented under Appendix **17**;

2 that, as soon as the ITU‑R studies are completed, a future competent
conference should consider necessary changes to Appendix **17** to
enable the use of new technology by the MMS,

invites ITU-R

to finalize studies currently ongoing:

-- to identify future requirements of the MMS;

-- to identify the technical characteristics necessary to facilitate use
of digital systems in the MF and HF bands allocated to the MMS, taking
into account any relevant ITU‑R Recommendations;

-- to identify the digital system(s) to be used in the MF/HF bands by
the MMS;

\- to identify any necessary modifications to the frequency table
contained within Appendix **17**;

\- identify maritime mobile HF spectrum for new systems, particularly in
the range 10 to 18 MHz.

\- identify additional spectrum resources in the range 9 to 10 MHz in
order to facilitate the introduction of new technologies in the mobile
maritime service, by overcoming the large gap between the 8 and 12 MHz
maritime mobile bands;

-- to propose a timetable for the introduction of new digital
technologies and any consequential changes to Appendix **17**;

-- to recommend how digital technologies can be introduced while
ensuring compliance with distress and safety requirements,

instructs the Secretary-General

to bring this Resolution to the attention of the International Maritime
Organization, the International Civil Aviation Organization, the
International Association of Marine Aids to Navigation and Lighthouse
Authorities and the Comité International Radio-Maritime.

**Reasons:** There are still several studies underway that need to be
completed prior to resolving this issue. These studies should be
completed prior to the next Conference, where the appropriate changes to
the RR can be considered.

**USA/ /3 SUP**

RESOLUTION 544 (WRC-03)

Identification of additional spectrum for the\
broadcasting service in the HF bands

**Reasons:** The impact to the Fixed and Mobile community is too severe
to allocate additional spectrum to the broadcasters that would, in fact,
come from bands assigned to these services. In addition, the long term
need for additional broadcasting spectrum is unknown.

**USA/ / 4 SUP**

RESOLUTION 729 (WRC-97)

Use of frequency adaptive systems in the MF and HF bands

**Reasons:** The studies under Resolution **729** have been completed.
These studies have indicated that no changes to the RR are required to
facilitate the introduction of adaptive techniques in the MF/HF bands.

**USA/ / 5 ADD**

RESOLUTION USA 1 (WRC-07)

Bandwidth Requirements for Advanced Fixed and Mobile HF Technologies in
the 3 -- 30 MHz Band

The World Radiocommunication Conference (Geneva, 2007),

considering

*a)* that there are a limited number of fixed and mobile 3 kHz bandwidth
channels, and many channel bandwidths are below 500 Hz, in the planned
portions of the 3-30 MHz band;

*b)* that trials of advanced fixed and mobile HF frequency systems have
demonstrated their feasibility and their associated spectrum efficiency;

*c)* that advanced fixed and mobile HF frequency systems require larger
channel bandwidth assignments which currently can only be accomplished
through channel bonding;

noting

that some advanced fixed and mobile HF frequency adaptive systems
utilize bandwidths of up to 12 kHz to support HF electronic messaging,
HF Internet, and HF file transfer;

resolves to invite ITU-R

1 to determine the feasibility of changing the Radio Regulations to
provide for the use of wider bandwidths to support advanced fixed and
mobile HF systems in the 3 -- 30 MHz band;

2 to bring the results of these studies to the attention of WRC‑10

**Reasons:** Urgent studies are required to determine the suitability of
changing the radio regulations to allow for wider bandwidths to the
fixed and mobile services to accommodate advanced HF adaptive systems.