DA 04-3580

November 15, 2004

**THE FCC'S ADVISORY COMMITTEE FOR THE**

**2007 WORLD RADIOCOMMUNICATION CONFERENCE PROPOSES PRELIMINARY**

**VIEWS ON WRC-07 ISSUES**

**IB Docket No. 04-286**

On November 10, 2004, the World Radiocommunication Conference Advisory
Committee (WRC-07 Advisory Committee) adopted preliminary views on a
number of issues that the 2007 World Radiocommunication Conference
(WRC-07) will address. The WRC-07 Advisory Committee was established by
the Commission in January 2004 to assist it in the development of
proposals for WRC-07. To that end, the WRC-07 Advisory Committee has
forwarded the recommendations it has developed since the beginning of
the year to the Commission for consideration. We have attached to this
Public Notice the WRC-07 Advisory Committee's latest recommendations,
which are in the form of "preliminary views". We appreciate the
substantial amount of work that the WRC-07 Advisory Committee has put
into developing its recommendations. This Public Notice requests
comments on all of these preliminary views.

Based upon our initial review of the recommendations forwarded to the
Commission, the International Bureau in coordination with other
Commission Bureaus and Offices tentatively concludes that we can
generally support the preliminary views recommended by the WRC-07
Advisory Committee. We seek comment on the recommendations that appear
in all of the WRC-07 Advisory Committee documents.

In addition, the National Telecommunications and Information
Administration (NTIA) has provided to the Commission a preliminary view
that was developed by the Executive Branch Agencies. We also request
comment on this preliminary view.

The comments provided will assist the FCC in its upcoming consultations
with the U.S. Department of State and NTIA in the development of U.S.
preliminary views. Once agreed by these agencies of the U.S. Government,
preliminary views will be used by U.S. delegations at bilateral,
regional and international meetings to stimulate discussion and to
attempt to achieve common proposals with other countries on the WRC-07
issues. The proposed preliminary views that are attached to this Public
Notice may evolve in the course of interagency discussions as we
approach WRC-07 and, therefore, do not constitute a final U.S.
Government position on any issue.

The complete text of these preliminary views and proposals is also
available in the FCC's Reference Information Center, Room CY-A257, 445
12^th^ Street, SW, Washington, DC 20554 or by accessing the FCC's WRC-07
world wide web site at: http://www.fcc.gov/wrc-07. To comment on the
preliminary views and proposals, please submit an original and one copy
of your comment to Alexander Roytblat, FCC WRC-07 Director, Federal
Communications Commission, Room 6-A865, 445 12^th^ Street, SW,
Washington, DC 20554. Comments should refer to IB Docket No. 04-286 and
to specific preliminary views by document number. Parties preferring to
e-mail their comments should address their comments to: wrc07@fcc.gov.
The deadline for comments on the proposed preliminary views is November
24, 2004. It is necessary that comments be received by November 24, 2004
to support the formulation of the U.S. positions in time for the meeting
of the Inter-American Telecommunication Commission, Permanent
Consultative Committee II, WRC-07 Working Group that is scheduled to
begin on December 6, 2004.

I.  **Recommendations on draft preliminary views by the Advisory
    Committee for the 2007 World Radiocommunication Conference:**

**[INFORMAL WORKING GROUP 1 (IWG-1)]{.underline}**

**[Terrestrial and Space Science Services]{.underline}**

**Document WAC/031(10.11.04):**

***[IWG-1 Modifications to RCS Draft Preliminary View for
WRC-07]{.underline}***

***Radio Conference Subcommittee (RCS)***

Preparation for ITU Radiocommunication Conferences

**DRAFT PRELIMINARY VIEW FOR WRC-07**

**WRC-2007 Agenda Item 1.20:** to consider the results of studies, and
proposals for regulatory measures, if appropriate, regarding the
protection of the Earth exploration-satellite service (passive) from
unwanted emissions of active services in accordance with Resolution
**738 (WRC--03)**.

**ISSUE**: [Compatibility between]{.underline}~~Protection of~~ the
Earth exploration-satellite (passive) service [and
the]{.underline}~~from unwanted emissions from~~ active services, in the
band pairs identified in the Table in Resolution **738** [while taking
account of all concerned services.]{.underline}

**BACKGROUND**: The 2003 World Radiocommunication Conference considered
studies pertaining to the protection of the Earth exploration-satellite
(passive) service from unwanted emissions under Agenda Item 1.8.2 and
developed Resolution **738** to address the issue. The WRC also included
the issue on the agenda for WRC--07, which is provided in
Resolution **802**.

Resolution **738** calls for continued studies of compatibility between
the Earth exploration-satellite (passive) service and unwanted emissions
from active services in seven pairs of active and passive service
frequency bands identified in the Table in the resolution. The active
services involved include the fixed, mobile, radiolocation,
fixed-satellite, inter-satellite and space research services.

Two other fixed service bands, 31--31.3 GHz and 51.4--52.6 GHz, are to
be evaluated for the impact of imposing specified limits for unwanted
emissions in adjacent EESS (passive) bands for Regions 2 and 3. The
impact on fixed-service systems in these bands in Region 1 has been
documented in Recommendation ITU--R SM.1633.

WRC--07 will review the results of the studies, in order to consider
regulatory measures, if appropriate, to ensure the protection of EESS
(passive) operating in the adjacent bands [indicated in the Table, and
taking into account the impact on all concerned services.]{.underline}.
The U.S. EESS (passive) community believes that Resolution **738**
contains all the EESS (passive) bands that need to be considered.

In addressing Agenda Item 1.8.2 at WRC--03, the United States took the
position that existing ITU--R regulations and Recommendations provide
sufficient protection to the Earth exploration-satellite (passive)
service, and that additional regulatory measures are not necessary.

[The Radiocommunications Bureau makes no examination regarding unwanted
emissions]{.underline}

**U.S. VIEW:**

-   The United States supports the use of existing ITU--R regulations
    and updating Recommendation ITU--R SM.1633 or developing additional
    Recommendations as the preferred means [of ensuring compatibility
    between]{.underline} ~~to provide protection to~~ the EESS (passive)
    [and active services in specified bands]{.underline}.

-   Acceptable solutions to this agenda item should provide adequate
    protection for EESS passive sensors, should not place an undue
    burden on the active services, should not require the involvement of
    the Radiocommunication Bureau and should not put an undue regulatory
    burden on administrations.

> [Including hard limits in the Radio Regulations for unwanted emissions
> from active services operating in the bands in the Table in Resolution
> **738 (WRC-03)** would be inconsistent with the second view
> above.]{.underline}

**[INFORMAL WORKING GROUP 3 (IWG-3)]{.underline}**

**[IMT-2000 and 2.5 GHz Sharing Issues]{.underline}**

**Document WAC/017(10.11.04):**

**DRAFT PRELIMINARY VIEWS ON WRC-07**

**WRC-07 Agenda Item 1.9:** to review the technical, operational and
regulatory provisions applicable to the use of the band 2 500-2 690 MHz
by space services in order to facilitate sharing with current and future
terrestrial services without placing undue constraint on the services to
which the band is allocated;

**ISSUE**: Matters related to the use of the bands 2500 - 2690 MHz by
terrestrial and space services.

**BACKGROUND**: The band 2500-2690 MHz is allocated for sharing by both
terrestrial and satellite services. The terrestrial services include the
Mobile and the Fixed Services (including IMT-2000). Both Services have
been rapidly evolving to encompass high speed mobile internet access
requiring sensitive receiving equipment some of which are highly
susceptible to interference.

The 2500-2690 MHz band is also allocated to the satellite services which
include MSS, BSS (including GSO and non-GSO), and FSS. At WRC-03, the
issue of sharing between terrestrial services and NGSO BSS(Sound) in
certain Region 3 countries was resolved with the revision of pfd limits
for NGSO BSS(Sound) per Resolution 539. GSO BSS(Sound) limits within
these countries were also tightened for systems for which complete
Appendix **4** coordination information has been received after
1 June 2005. Other than for these Region 3 countries, the BSS limits
remained the same as given in Table 21-4 of the Radio Regulations.
WRC-03 recognized the difficulty of sharing between the terrestrial and
satellite services and caused the ITU-R to form Joint Task Group 6-8-9
to study the issues related to sharing.

In general, co-frequency sharing between the mobile-satellite service
(MSS) and terrestrial services has been found to be difficult in the
ITU-R studies. The sharing between the terrestrial services and the MSS
poses risks of harmful interference to both systems. In addition, it
will require large separation distance between terrestrial stations and
MSS earth stations in order to avoid harmful interference to both
stations. Recommendation M.2041 studied the feasibility of sharing
between MSS and MS for IMT-2000 and highlighted the incompatibility
between these two services on a co-frequency basis.

Both BSS and FSS are also allocated to the 2500-2690 MHz band and are
subject to the limits in Table 21-4. Within Region 2 any satellite
service launched may overlap many other Region 2 countries and have the
effect of interfering with existing and planned terrestrial services
within that band.

Administrations in Region 2 are planning for implementation of
terrestrial services in the 2500-2690 MHz band (See WP-8F questionnaire
to administrations and summary in attached Annex). In the United States
there are no allocations to space services in this band.

**UNITED STATES VIEW**:

1.  The United States supports the ongoing studies on sharing between
    satellite and terrestrial services in the 2500 -- 2690 MHz band
    being conducted in JTG 6-8-9 with the view that adequate protection
    from satellite interference must be secured for its existing and
    future terrestrial systems.

2.  Recognizing that implementations of satellite services by any Region
    2 country will affect terrestrial services within other Region 2
    countries and that administrations in Region 2 plan to implement
    terrestrial services in the band 2500 - 2690 MHz, the United States
    is of the view that allocations to satellite services in the band
    2500 - 2690 MHz in Region 2 may prove disruptive to terrestrial
    deployments.

3.  The United States is of the view that studies should focus on the
    effects of interference on terrestrial systems by space services.

4.  Since administrations in Region 2 have no plans to implement MSS
    systems in the band 2500 -- 2690 MHz, the United States is of the
    view that primary allocations to MSS in the band 2500 -- 2690 MHz in
    Region 2 are no longer required.

5.  The United States supports NOC to RR Footnotes 5.417A and 5.418 as
    adopted by WRC-03 relating to non-GSO and GSO BSS (sound) systems in
    the band 2605-2655 MHz.

Annex 1\
\
Summary of responses to the questionnaire

How is the band 2 500-2 690 MHz presently allocated and used in your
country?

+----------+---+-----------------------------------------------------------+
| UAE\     |   | It is allocated and extensively used by fixed and mobile  |
| Doc.     |   | services.                                                 |
| 8F/184   |   |                                                           |
+----------+---+-----------------------------------------------------------+
| Brazil\  |   | a\) 2 500-2 520: Fixed (RR 5.409 and 5.411 apply), mobile |
| Doc.     |   | and mobile satellite - Earth to space (RR 5.403 and       |
| 8F/177   |   | 5.351A apply)[^1];                                        |
|          |   |                                                           |
|          |   | b\) 2 520-2 655: Fixed (RR 5.409 and 5.411 apply) and     |
|          |   | mobile[^2];                                               |
|          |   |                                                           |
|          |   | c\) 2 655-2 670: Fixed (RR 5.409 and 5.411 apply) and     |
|          |   | mobile[^3];                                               |
|          |   |                                                           |
|          |   | d\) 2 670-2 690: Fixed (RR 5.409 and 5.411 apply), mobile |
|          |   | and mobile satellite -- space to Earth (Note 5.351A       |
|          |   | applies)[^4].                                             |
|          |   |                                                           |
|          |   | However, the band is primarily used for the multipoint    |
|          |   | multichannel distribution service, a modality of pay-TV   |
|          |   | service, which is a fixed service[^5]. On a secondary     |
|          |   | basis, the band is used for TV broadcasting relay systems |
|          |   | and electronic news gathering.                            |
+----------+---+-----------------------------------------------------------+
| Mexico\  |   | The 2 500-2 690 MHz band is currently attributed and      |
| Doc.     |   | licensed for MMDS and MDS (restricted TV and wireless     |
| 8F/167   |   | Internet access) services.                                |
+----------+---+-----------------------------------------------------------+
| C        |   | The band 2 500-2 690 MHz is currently heavily used for    |
| ameroon\ |   | the fixed service by short range microwave links for      |
| Doc.     |   | inter-switch connections in the main cities (Douala,      |
| 8F/160   |   | Yaoundé).                                                 |
+----------+---+-----------------------------------------------------------+
| Japan\   |   | The band 2 500-2 535 MHz and 2 655-2 690 MHz is used for  |
| Doc.     |   | MSS, downlink and uplink respectively. The band 2 605-2   |
| 8F/136   |   | 655 MHz is planned to be used for BSS.                    |
+----------+---+-----------------------------------------------------------+
| Korea\   |   | Wireless CATV is allocated in this band and satellite DMB |
| Doc.     |   | services are also allocated in parts of the band of       |
| 8F/133   |   | Wireless CATV as results of prior WRCs. According to      |
|          |   | obligation of the wireless CATV, the bands allocated to   |
|          |   | satellite DMB services should be available whenever the   |
|          |   | services begin to be deployed. Several parts of the band  |
|          |   | 2 500-2 690 MHz are now utilized for supporting           |
|          |   | broadcasting services on a license basis.                 |
+----------+---+-----------------------------------------------------------+
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|          | . |                                                           |
+----------+---+-----------------------------------------------------------+

+-----------+----------------------------------------------------------+
| Canada\   | In Canada, the entire band 2 500-2 690 MHz has primary   |
| Doc.      | allocations to the fixed and mobile services and in      |
| 8F/118    | addition, an allocation to the broadcasting service in   |
|           | the upper portion of the band (2 596-2 686 MHz).         |
|           |                                                          |
|           | The lower portion of the band (2 500-2 596 MHz) is used  |
|           | for multipoint communications systems (MCS) to advance   |
|           | local distribution of telecommunications services. The   |
|           | upper portion (2 596-2 686 MHz) is used for multipoint   |
|           | distribution system (MDS) to support local broadcasting  |
|           | distribution undertakings. There are currently no        |
|           | operators authorized in the mobile service.              |
+-----------+----------------------------------------------------------+
| China\    | The band 2 535-2 599 MHz has been used for MMDS system.  |
| Doc.      |                                                          |
| 8F/115    |                                                          |
+-----------+----------------------------------------------------------+
| CEPT\     | The band 2 500-2 690 MHz is currently allocated in CEPT  |
| Doc.      | to the fixed and mobile services for a variety of        |
| 8F/110    | applications such as ENG/OB (programme-making), Wireless |
|           | Local Loop, Point to Point Systems, etc.                 |
+-----------+----------------------------------------------------------+
| Sultanate | Part of the band is allocated so far to fixed and        |
| of Oman   | broadcasting satellite.                                  |
+-----------+----------------------------------------------------------+
| State of  | The band 2 500-2 690 MHz is allocated to fixed services. |
| Qatar     |                                                          |
+-----------+----------------------------------------------------------+

Does your Administration have any future plans to change the allocations
and\
future use of the band 2 500-2 690 MHz? If so, in what time frame?

+-----------+----------------------------------------------------------+
| UAE\      | No plans.                                                |
| Doc.      |                                                          |
| 8F/184    |                                                          |
+-----------+----------------------------------------------------------+
| Brazil\   | The Brazilian Administration has, so far, no plan for    |
| Doc.      | introducing IMT-2000 on this band. However, once the     |
| 8F/177    | long term prospects for the MMDS and the further         |
|           | regulation for the use of this band is established by    |
|           | ITU (i.e. FDD and TDD distribution on the band), Brazil  |
|           | understands that worldwide this band has potential for   |
|           | supporting the rapid development of IMT-2000 and beyond, |
|           | making easier to obtain the scale needed for it.         |
+-----------+----------------------------------------------------------+
| Mexico\   | Mexico has not defined the time frame when the           |
| Doc.      | attribution of this band could be changed. It will       |
| 8F/167    | depend on the market conditions as well as the           |
|           | introduction of new services and technologies. As of     |
|           | today, Mexico considers that the planned IMT‑2000        |
|           | capacity in other identified bands is enough in the long |
|           | term.                                                    |
+-----------+----------------------------------------------------------+
| Cameroon\ | No modification of the attributions in this band is      |
| Doc       | envisaged for the moment.                                |
| 8F/160    |                                                          |
+-----------+----------------------------------------------------------+
| Japan\    | Japan has no plan to change the "Frequency Assignment    |
| Doc.      | Plan". It has already been assigned to the mobile        |
| 8F/136    | service.                                                 |
+-----------+----------------------------------------------------------+
| Korea\    | No. There is no announcement of Administration to change |
| Doc.      | the allocation of the band 2 500-2 690 MHz up to now.    |
| 8F/133    |                                                          |
+-----------+----------------------------------------------------------+
| USA\      | There are no plans to make any further allocation        |
| Doc.      | changes to the 2 500-2 690 MHz band in the U.S. at this  |
| 8F/122    | time.                                                    |
|           |                                                          |
|           | In early 2003, the U.S. Federal Communications           |
|           | Commission (FCC) instituted a rulemaking proceeding for  |
|           | this band by issuing a Notice of Proposed Rulemaking to  |
|           | "facilitate the provision of fixed and mobile broadband  |
|           | access, educational and other advanced services" in this |
|           | band. It is expected that an Order(s) will be released   |
|           | sometime during the first half of 2004, which will       |
|           | contain sharing criteria and modified rules for use of   |
|           | this band, along with a revised frequency arrangement.   |
+-----------+----------------------------------------------------------+
| Canada\   | The entire band 2 500-2 690 MHz is allocated to both the |
| Doc.      | fixed and mobile service with an additional allocation   |
| 8F/118    | to broadcasting in the upper portion as specified in     |
|           | response to question 1. There are no allocation changes  |
|           | being considered. Current users of the band are          |
|           | authorized to provide fixed and broadcasting services.   |
|           | Canada has announced that it will conduct a public       |
|           | consultation in the 2004 time frame to address licensing |
|           | issues in the band including the use of mobile.          |
+-----------+----------------------------------------------------------+
| China\    | Currently no plan to change the allocation.              |
| Doc.      |                                                          |
| 8F/115    |                                                          |
+-----------+----------------------------------------------------------+
| CEPT\     | In most CEPT countries existing systems will be phased   |
| Doc.      | out so that the spectrum will be available for           |
| 8F/110    | UMTS/IMT-2000 by 1 January 2008.                         |
+-----------+----------------------------------------------------------+
| Sultanate | There are no plans but dependent on market demand.       |
| of Oman   |                                                          |
+-----------+----------------------------------------------------------+
| State of  | No future plan to change the allocation. The band 2      |
| Qatar     | 400-2 700 MHz has already assigned to MMDS. MMDS system: |
|           | Stands for multipoint multi-channel distribution system  |
|           | or microwave multi-channel distribution system.          |
+-----------+----------------------------------------------------------+

\_\_\_\_\_\_\_\_\_\_\_\_\_

**[INFORMAL WORKING GROUP 4 (IWG-4)]{.underline}**

**[Broadcasting and Amateur Issues]{.underline}**

**Document WAC/032(10.11.04):**

**DRAFT PRELIMINARY VIEWS ON WRC-07**

**Agenda Item 1.6**: *to consider additional allocations for the
aeronautical mobile (R) service in parts of the bands between 108 MHz
and 6 GHz, in accordance with Resolution **414** **(WRC‑03)** and, to
study current satellite frequency allocations, that will support the
modernization of civil aviation telecommunication systems, taking into
account Resolution **415 (WRC‑03)**;*

**NOTE:** **IWG-4** is responsible for Resolution **414** portion of AI
1.6.

**IWG-2** is responsible for Resolution **415** portion of AI 1.6

This IWG-4 Preliminary View addresses Resolution **414** only.

**ISSUES & EFFORTS**: Resolution 414 of this agenda item addresses
several issues and efforts:

1\. **ISSUE**: That the current aeronautical mobile band 117.975-137 MHz
will become saturated in some areas of the world and will no longer be
able to support increasing and/or new requirements.

> 2\. **ISSUE:** That any allocation changes in the band 108-117.975 MHz
> shall place no additional constraints on the broadcasting service or
> cause harmful interference to stations of the broadcasting service
> operating in the band 87-108 MHz in the U.S. RR 5.43 does not apply to
> systems identified in recognizing (d) of Resolution 413.
>
> 3\. **EFFORT:** That Res. **114** **(Rev.WRC-03)** and Res. **413**
> **(WRC-03),** call for compatibility studies in the relevant
> aeronautical bands.
>
> 4\. **EFFORT:** To determine if additional allocations for
> aeronautical mobile (route) service (AM(R)S) are necessary and/or
> should be made in the frequency range 108 MHz to 6 GHz:
>
> a\. to consider adding AM(R)S allocations to existing aeronautical
> bands; and
>
> b\. if step a. is not sufficient, to consider adding AM(R)S
> allocations to bands that are not currently used by aviation.
>
> 5\. **EFFORT:** To specifically consider how to accommodate the
> requirements for aeronautical systems in the band 5 091-5 150 MHz.

**BACKGROUND**: Efforts addressed in Res. 414 in this agenda item are:

1\. To investigate the bands currently available for use by aeronautical
systems in the frequency range between 108 MHz and 6 GHz in order to
determine whether additional allocations to the aeronautical mobile (R)
service are required and can be accommodated in these bands without
placing undue constraints to services to which the frequency bands are
currently allocated;

2\. To further investigate, in case the first step above would not lead
to satisfactory results, also the frequency bands currently not
available for use by aeronautical systems, subject to not constraining
the existing and planned use of such bands, taking account of existing
use and future requirements in these bands;

3\. To investigate how to accommodate the requirements for aeronautical
systems in the band 5 091-5 150 MHz,

**DISCUSSION:**

1\. At WRC-03 an additional allocation (5.197A) for the 108-117.975 MHz
ARNS band was enacted. That allocation, for AM(R)S limited to systems
that transmit navigational information in support of air navigation and
surveillance functions in accordance with recognized international
aviation standards, required that such use be in accordance with
Resolution 413 (WRC-03). Resolution 413 addressed the need for studies
between aeronautical and broadcast services to address compatibility
issues that might arise from the introduction of new systems in either
service.

2\. WRC-03 identified the need for studies to consider how to
accommodate the requirements for aeronautical systems in the band 5
091-5 150 MHz. Although this might be considered a subset of the first
effort, as most proposed applications for this frequency band would fit
under AM(R)S, the scope of this effort is broader in that aeronautical
fixed links are also being considered to allow transmission of
aeronautical sensor data on the airport property without requiring
costly underground cable installation.

**U.S. VIEWS**: [With regard to Resolution 414 (WRC-03)]{.underline}:

1\. The U.S. views that current aviation communication bands are
severely congested. In addition, recent experience has shown that
evolving technology for navigation and surveillance functions may
necessitate allocations that are more encompassing than simply the
aeronautical radionavigation service (ARNS). As a result, the U.S.
anticipates supporting the addition of AM(R)S allocations in some
frequency bands depending on the results of ITU-R studies. The U.S. view
is also to maintain compatibility with services in adjacent bands. In
particular, the U.S. is of the view that any allocation changes in the
108-117.975 MHz band must be compatible with terrestrial broadcasting
systems and place no additional constraints on the broadcasting service
in the band 87-108 MHz in the United States.

2\. In case the first step above would not lead to satisfactory results,
the U.S. supports further investigation of frequency bands currently not
available for use by aeronautical systems, subject to not constraining
the existing and planned use of such bands, taking account of existing
use and future requirements in these bands.

3\. The U.S. views that investigation may be necessary to determine how
to accommodate the requirements for aeronautical systems in the band
5 091-5 150 MHz, including the possibility of fixed service links
limited to aeronautical applications at airports. In this regard the
United States will seek to ensure that the operations of the existing
FSS consistent with 5.444A are taken into account. (November 1, 2004)

**[INFORMAL WORKING GROUP 5 (IWG-5)]{.underline}**

**[Regulatory Issues]{.underline}**

**Document WAC/034(10.11.04):**

**DRAFT PRELIMINARY VIEWS ON WRC-07**

**WRC-07 Agenda Item 1.1**: requests from administrations to delete
their country footnotes or to have their country name deleted from
footnotes, if no longer required, in accordance with Resolution **26
(Rev.WRC‑97)**

**ISSUE**: Deletion of country footnotes or country names from existing
country footnotes to the Table of Frequency Allocations in Article **5**
of the Radio Regulations.

**BACKGROUND**: Resolution **26 (Rev.WRC‑97)** urges administrations to
review footnotes periodically and to propose the deletion of their
country footnotes or of their country names from footnotes, as
appropriate. In exceptional cases, the resolution provides that
proposals for new footnotes or modifications of existing footnotes can
be considered if they concern corrections of obvious omissions,
inconsistencies, ambiguities or editorial error.

In addition to the usual deletion of names from country footnotes called
for under Resolution **26 (Rev.WRC‑97)** and standing agenda item 1.1,
WRC-03 and other recent conferences have permitted consideration of
proposals for the addition of country names to existing footnotes
submitted by a firm deadline during the Conference. Such proposals were
accepted only under the express condition that no objections were
received from affected countries.

**U.S. VIEW**: In dealing with this agenda item, WRC-07 should continue
to follow the precepts of Resolution **26 (Rev.WRC‑97**), which
encourages countries to delete their names from country footnotes, and
should adopt the approach used for this agenda item at WRC-03 and
previous conferences. (6.28.04)

**Document WAC/035(10.11.04):**

**DRAFT PRELIMINARY VIEWS ON WRC-07**

**WRC-07 Agenda Item 1.12**: to consider possible changes in response to
Resolution 86 (Rev. Marrakesh, 2002) of the Plenipotentiary Conference:
"Advance publication, coordination, notification and recording
procedures for frequency assignments pertaining to satellite networks"
in accordance with Resolution 86 (WRC-03).

**ISSUE:** "Rationalization and Clarification of Articles 9 and 11"

In addition to Resolution 86 (WRC-03) itself, WRC-03 adopted Resolution
88 that addresses potential rationalization and clarification of
Articles 9 and 11 of the Radio Regulations. Resolution 88 suggests that
rationalization of Articles 9 and 11 could be considered under
Resolution 86 at a future competent Conference. An initial issue with
respect to Resolution 88 is whether specific problems that have arisen
in application of Articles 9 and 11 should be addressed on case-by-case
basis, or whether a more comprehensive overhaul of the Articles should
be undertaken.

**BACKGROUND:** Since the early 1990's, the ITU has seen many proposals
to modify the Radio Regulations. Some of the efforts have been more
extensive and far-reaching than others. For example, the VGE, or
Voluntary Group of Experts, was established with the intent of
simplifying the Radio Regulations. The result was a new "simplified" set
of regulations adopted at WRC-95, which were designated with an "S"
proceeding the Article and Appendix numbers (e.g., in the 1998 Edition
of the Radio Regulations). That effort resulted in significant changes
to the Radio Regulations (replacement of Article 14 with No. 9.21,
incorporation of Resolution 46 into Article 9, etc). While these changes
were well-intended, the new provisions resulted in extensive Rules of
Procedures that were subsequently developed. This process demonstrates
that many new regulations may require detailed new interpretations. It
would be expected that any extensive revisions to Articles 9 and 11
adopted by future conferences, would similarly require such detailed
Rules of Procedure to be developed, despite an intention to adopt clear
regulations. In accordance with No. 13.0.1, the Radio Regulations Board
would then submit the necessary modifications to the Radio Regulations
to a subsequent WRC to alleviate the difficulties or inconsistencies
that the current Rules of Procedure address.

The process of developing any extensive revisions to Articles 9 and 11,
and then the process of developing associated Rules of Procedure, will
leave administrations and operators with uncertainty on how to
successfully apply the coordination and notification processes to
implement satellite networks and may also require transition procedures.
Such uncertainty, particularly over the span of years, could undermine
the industry. Satellite operators need a stable regulatory environment
in which to implement systems. Further, extensive changes to rationalize
the Radio Regulations could lead to many unintended substantive changes.
Changes to the Radio Regulations are safer and easier for
Administrations to review and analyze when proposed on a case-by-case
basis, with supporting justification for each change. In this way, any
untoward consequences of a particular change can be more readily
identified.

Another issue the ITU has been struggling with is how to manage the
extensive development of satellite networks and their associated filings
at the ITU-BR. Such developments have put a strain on the application of
the Radio Regulations by the BR, which has the responsibility for the
processing and examination of the advance publications, coordination
requests and notifications of satellite networks. Additional extensive
revisions to the Radio Regulations will increase the administrative and
financial burden on ITU and BR resources, as software will need to be
modified or developed to process filings according to the new provisions
and new Rules of Procedures will need to be developed, etc. No doubt any
further "rationalization" of the Regulations would further complicate
the Satellite Cost Recovery program as there would be a transition
period of time in which the staff would need to learn how to apply the
"rationalized" procedures.

In summary, there appear to be few benefits and many potential
detriments to a wholesale "rationalization" of Articles 9 and 11 of the
Radio Regulations even with minimal substantive revisions.

**U.S. Views:**

The U.S. supports selective modification of the Radio Regulations to
remedy specific issues that have arisen with application of Articles 9
and 11, and is opposed to an extensive revision of those Articles.
Administrations and satellite operators need a stable regulatory process
in order to successfully implement and operate satellite networks.

> **II. A Draft Preliminary View**[^6] **approved by the National
> Telecommunications and Information Administration:**

Donald Abelson

Chief, International Bureau

Federal Communications Commission

445 12^th^ Street S.W.

Washington, D.C. 20554

Dear Mr. Abelson:

The National Telecommunications and Information Administration on,
behalf of the Executive Branch Agencies, wishes to bring to your
attention an additional approved draft preliminary Executive Branch view
considering federal agency inputs toward the development of the U.S.
Preliminary Views for WRC-2007. The enclosed draft preliminary view
addresses agenda item 1.20.

The enclosure is forwarded for review by the Commission. Jim Vorhies of
my staff is the primary contact for NTIA.

Sincerely

*Original Signed September 30, 2004*

> Fredrick R. Wentland
>
> Associate Administrator
>
> Office of Spectrum Management

Enclosure

***Radio Conference Subcommittee (RCS)***

Preparation for ITU Radiocommunication Conferences

**DRAFT PRELIMINARY VIEW FOR WRC-07**

**WRC-2007 Agenda Item 1.20:** to consider the results of studies, and
proposals for regulatory measures, if appropriate, regarding the
protection of the Earth exploration-satellite service (passive) from
unwanted emissions of active services in accordance with Resolution
**738 (WRC--03)**.

**ISSUE**: Protection of the Earth exploration-satellite (passive)
service from unwanted emissions from active services, in the band pairs
identified in the Table in Resolution **738**

**BACKGROUND**: The 2003 World Radiocommunication Conference considered
studies pertaining to the protection of the Earth exploration-satellite
(passive) service from unwanted emissions under Agenda Item 1.8.2 and
developed Resolution **738** to address the issue. The WRC also included
the issue on the agenda for WRC--07, which is provided in
Resolution **802**.

Resolution **738** calls for continued studies of compatibility between
the Earth exploration-satellite (passive) service and unwanted emissions
from active services in seven pairs of active and passive service
frequency bands identified in the Table in the resolution. The active
services involved include the fixed, mobile, radiolocation,
fixed-satellite, inter-satellite and space research services.

Two other fixed service bands, 31--31.3 GHz and 51.4--52.6 GHz, are to
be evaluated for the impact of imposing specified limits for unwanted
emissions in adjacent EESS (passive) bands for Regions 2 and 3. The
impact on fixed-service systems in these bands in Region 1 has been
documented in Recommendation ITU--R SM.1633.

WRC--07 will review the results of the studies, in order to consider
regulatory measures, if appropriate, to ensure the protection of EESS
(passive) operating in the adjacent bands. The U.S. EESS (passive)
community believes that Resolution **738** contains all the EESS
(passive) bands that need to be considered.

In addressing Agenda Item 1.8.2 at WRC--03, the United States took the
position that existing ITU--R regulations and Recommendations provide
sufficient protection to the Earth exploration-satellite (passive)
service, and that additional regulatory measures are not necessary.

**U.S. VIEW:**

-   The United States supports the use of existing ITU--R regulations
    and updating Recommendation ITU--R SM.1633 or developing additional
    Recommendations as the preferred means to provide protection to the
    EESS (passive).

-   Acceptable solutions to this agenda item should provide adequate
    protection for EESS passive sensors, should not place an undue
    burden on the active services, should not require the involvement of
    the Radiocommunication Bureau and should not put an undue regulatory
    burden on administrations.

-FCC-

[^1]: RR 5.407 and 5.414 apply for the entire band.

[^2]: RR 5.339 and 5.403 apply for the entire band.

[^3]: RR 5.149 and 5.420 apply for the entire band.

[^4]: RR 5.149, 5.419 and 5.420 apply for the entire band.

[^5]: Note should be give to the fact that this situation is shared by
    many countries in the Region 2.

[^6]: ^^ Note: The Advisory Committee for the 2007 World
    Radiocommunication Conference recommended modifications to the draft
    preliminary view approved by NTIA. The advisory committee's
    recommendation appears in Section I of this public notice under
    Informal Working Group 1.