DA 04-1698

June 14, 2004

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

**2007 WORLD RADIOCOMMUNICATION CONFERENCE PROPOSES PRELIMINARY**

**VIEWS ON WRC-07 ISSUES**

On June 8, 2004, the World Radiocommunication Conference Advisory
Committee (WRC-07 Advisory Committee) adopted preliminary views on
numerous 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 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 most of the preliminary views recommended by the
WRC-07 Advisory Committee. We do, however, find the preliminary views
reflected in documents WAC/015 and WAC/026, to be premature or
inconsistent with current Commission policies. We seek comment on the
recommendations that appear in all of the WRC-07 Advisory Committee
documents and on our initial impressions of which preliminary views we
can support.

In addition, the National Telecommunications and Information
Administration (NTIA) has submitted to the Commission preliminary views
that have been developed by the Executive Branch Agencies. We also
request comment on these preliminary views.

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 these
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 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 July** **2, 2004. It is
necessary that all comments be received by July 2, 2004 in order to
allow us to finalize the U.S. position before commencement of regional
WRC-07 preparatory meetings.

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

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

**UNITED STATES**

**DRAFT PRELIMINARY VIEWS ON WRC-07**

(Res.746)

**AGENDA ITEM 1.2: t**o consider allocations and regulatory issues
related to the Earth Exploration Satellite (passive) Service, space
research (passive) service, and the meteorological satellite service in
accordance with Resolutions 746 (WRC-03) and 742 (WRC-03).

# ISSUE:

This Preliminary View only addresses the 18 GHz aspects of Resolution
746 (WRC-03). For this case, the issue is the feasibility of sharing
between meteorological satellites operating in the space-to-Earth
direction and the fixed service and fixed satellite service in the
space-to-Earth direction in the band 18.0-18.4 GHz. (Resolution 746)

# BACKGROUND:

Resolution 746 indicates that a space-to-Earth meteorological allocation
exists in the band 18.1-18.3 GHz, but that this allocation is not wide
enough to support the data rates viewed as necessary by the Metsat
service. The Metsat service wishes to use geostationary satellites to
provide this service.

The band 18.0-18.4 GHz is allocated to the FSS in the space-to-Earth
direction and in the Earth-to-space direction. The Earth-to-space
allocations are limited to use by BSS feederlinks with the 18-18.1 GHz
segment being part of the Appendix 30A BSS feederlink Plan for Regions 1
and 3, and the 18.1-18.4 GHz segment being non-planned. In the 18-18.4
GHz band GSO satellites, including Metsats in the band 18.1-18.3 GHz
band, are subject to coordination under No. 9.7 (and coordination
threshold of ΔT/T = 6%).

Article 21 pfd limits for GSO FSS in the band 18.0-18.4 GHz range from
--105 dB W/m^2^. MHz) to --115 dB (W/m^2^. MHz)) depending on angle of
arrival. GSO FSS systems are either operating or being designed to
operate up to these levels. Further, GSO FSS systems in these bands
operate with small orbital spacing, e.g., 2º. In Region 2, the 18.3-19.3
GHz band was identified by WRC-03 \[No. 5.516B\] for deployment of High
Density FSS (HDFSS) earth stations, and thus plans for use of the
18.3-18.4 GHz band by high power satellites operating with ubiquitously
deployed small Earth stations are well advanced.

BSS feeder links systems generally use a relatively small number of
large feeder link earth stations, which may facilitate the sharing
situation for the terrestrial paths (FSS earth station interfering into
MetSat receiving earth stations).

ITU-R WP-7B has the lead in preparing CPM text for this agenda item and
WP-4A has identified a Rapporteur to participate in its work.

# U.S. VIEW:

1.  The FSS is planning and designing geostationary satellite systems
    for use of the band 18.3-18.4 GHz, including FSS systems currently
    under construction in the US, under the technical and regulatory
    constraints presently found in the Radio Regulations. The United
    States has implemented HDFSS in the 18.3-18.8 GHz bands, through
    allowing blanket licensing of FSS earth stations. In addition, to
    facilitate ubiquitous deployment of small earth stations, the United
    States has removed terrestrial allocations in this band. Considering
    this, any extension of the MetSat allocation into the 18.3-18.4 GHz
    band cannot impose any additional constraints on the FSS.

2.  While the ITU-R is continuing to study this issue, the sharing
    conditions that result as a consequence of the protection
    requirement for the MetSat service, that were communicated to ITU-R
    WP 4A, would impose unacceptable constraints on the FSS.

3.  If it is not possible to meet the Metsat data transmission bandwidth
    requirements in the already established 18.1-18.3 GHz Metsat
    allocation, consideration should be given to extending the
    allocation to 18.0-18.3 GHz due to the difficulty of sharing between
    HDFSS GSO FSS systems and Metsats in 18.3-18.4 GHz.

# UNITED STATES

# DRAFT PRELIMINARY VIEWS ON WRC-07

**WRC-07 Agenda Item 1.5:** to consider spectrum requirements and
possible additional spectrum allocations for aeronautical telecommand
and high bit-rate aeronautical telemetry.

**ISSUE**: This agenda item seeks to satisfy requirements for additional
wideband aeronautical mobile telemetry, and associated telecommand,
spectrum above 3 GHz. Methods for resolving the issue will entail
sharing studies with existing services and continued protection of
incumbent services.

**BACKGROUND**: This agenda item has its origins in efforts undertaken
by the aerospace industry prior to WRC-97. The issue was pursued by the
U.S. and other Administrations at WRC-03 and placed on the agenda for
WRC-07. In addition, CITEL adopted an IAP in support of the agenda item,
which was supported by the U.S. and numerous other Region 2
Administrations. The agenda item seeks to address a large and growing
shortfall in the spectrum available to conduct aeronautical telemetry.
The shortfall is due to rapidly increasing telemetry data rates
associated with the testing of new technologies. It has been exacerbated
by the loss of telemetry spectrum diverted to other applications such as
mobile and broadcast satellite. Without additional spectrum, U.S.
aeronautical development increasingly will be subject to program delays,
escalating costs, and impaired competitiveness in the global
marketplace. These factors will impact equipment manufacturers,
airlines, civil test programs, and, ultimately, the traveling public.
Additional worldwide telemetry allocations will also aid other nations
inasmuch as many Administrations maintain and operate National air
carriers, and several are initiating space programs of their own.

**U.S. VIEW**: The United States supports additional spectrum
allocations for aeronautical telemetry. Once the ITU-R studies are
completed, the U.S. can make a proposal regarding the methods by which
the agenda item can be best satisfied.

**[INFORMAL WORKING GROUP 2 (IWG-2)]{.underline}**

**UNITED STATES**

**DRAFT PRELIMINARY VIEWS ON WRC-07**

**WRC-07 Agenda Item 1.6 (Res. 415 (WRC-03) only):** 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)**;

**ISSUE**: How broadening the services and applications of current
satellite frequency allocations that could support civil aviation
telecommunications systems can be made compatible with existing uses and
at the same time encourage the deployment of a satellite infrastructure
that can be used for other non-aeronautical telecommunications services.

**BACKGROUND**:

The objective behind Resolution 415 is to identify satellite spectrum
that could, compatibly with current allocations and uses, support
additional applications that could be used for aviation-related services
that modernize and are supportive of International Civil Aviation
Organization (ICAO) Communication, Navigation & Surveillance/ Air
Traffic Management (CNS/ATM) systems. Special emphasis is placed on the
extension of these modernized systems to developing countries and remote
areas that do not have terrestrial infrastructure.

With ever increasing speed, existing and new communications systems are
being based on Internet related protocols and services. Access to these
services with sufficient bandwidth is becoming essential for both
terrestrial and aeronautical communications. Without this access
aeronautical operations will be hindered from gaining the efficiencies
and benefits that this type of service offers. The development of
satellite facilities to support aeronautical operations can also support
the extension or enhancement of non-aeronautical telecommunications
services to developing countries and remote areas.

Some African countries have indicated that the problems of providing
CNS/ATM services to remote airports in some developing countries, and
some developed countries with underdeveloped infrastructure, can be
eased through the application of satellite-based solutions. Further,
they say that in order to promote improved communication capabilities in
general, these improved, satellite-based, facilities should be shared
with non-aviation users to increase affordability.

The ITU-R recognized that the use of the 14.0-14.5 GHz band for
Aeronautical Mobile Satellite Service (AMSS) on a Secondary basis, an
allocation added at WRC-03, was compatible with current Fixed Satellite
Service (FSS) systems and was supported by studies leading up to WRC-03.
Studies within the ITU-R assessed compatibility of the usage of the
11/12 GHz downlink band, associated with the 14 GHz uplink band, and
found that these downlink signals could co-exist with FSS systems.

**U.S. VIEWS**:

1.  That existing Fixed Satellite Service (FSS) spacecraft and
    appropriate earth stations can be used to create, augment or enhance
    infrastructure to support civil aviation telecommunications
    services, including non-safety related ICAO CNS/ATM applications.

2.  The use of satellite-based facilities in connection with civil
    aviation applications mentioned above will contribute to the overall
    improvement of the communications infrastructure in developing
    countries and remote areas and allow ready access to Internet based
    services. However, since these latter applications are already
    consistent with existing satellite frequency allocations and can be
    supported by existing or planned satellite networks, no action from
    WRC-07 is required in this respect.

3.  That the extension of broadband digital access to aeronautical
    platforms is a necessary step in the modernization of civil aviation
    telecommunications systems and that this extension can be
    facilitated through the Aeronautical Mobile Satellite Service (AMSS)
    operating in the 14/11/12 GHz bands. There is currently no AMSS
    downlink allocation and downlink signals operate under RR 4.4 in the
    11/12 GHz band. The matching of the secondary AMSS uplink in the 14
    GHz band with a secondary downlink allocation in the 11/12 GHz band
    would aid in the acceptance and standardization of these non-safety
    applications for aviation use.

**UNITED STATES**

**DRAFT PRELIMINARY VIEWS ON WRC-07**

**WRC-07 Agenda Item 1.8 (Res. 122 (Rev.WRC-03) only):** to consider the
results of ITU-R studies on technical sharing and regulatory provisions
for the application of high altitude platform stations operating in the
bands 27.5-28.35 GHz and 31‑31.3 GHz in response to Resolution **145**
**(WRC‑03),** and for high altitude platform stations operating in the
bands 47.2-47.5 GHz and 47.9-48.2 GHz in response to Resolution **122
(Rev.WRC‑03)**;

**ISSUE**: Matters related to the use of the bands 47.2-47.5 GHz and
47.9-48.2 GHz by high altitude platform stations (HAPS) in the fixed
service and by systems and networks in the fixed-satellite service
(FSS).

**BACKGROUND**: The ITU has been considering the implications of HAPS in
the fixed service in the 47.2-47.5 GHz and 47.9-48.2 GHz band since
1997, when WRC-97 first made provision for the operation of HAPS within
the fixed service. Studies have been ongoing under versions of
Resolution 122 since WRC-97.

In the WRC-2000 revision to Resolution 122, the ITU-R was requested to
complete sharing studies between the FSS and HAPS operations in the
fixed service. Following WRC-2000, Recommendation ITU-R SF.1481 was
developed and adopted. This recommendation makes clear that co-frequency
operations between HAPS in the fixed service and FSS networks and
systems is feasible in the 47.2-47.5 GHz and 47.9-48.2 GHz bands (even
though it was noted that "there may be a need to develop the maximum
allowable power flux-density at satellites on the GSO due to aggregate
interference caused by ground user terminals of high altitude platform
networks").

In the revision to Resolution 122 approved at WRC-03, co-existence
between HAPS in the FS and the FSS at 47.2-47.5 GHz and 47.9-48.2 GHz
was presumed feasible, as administrations were encouraged to facilitate
interservice coordination. The ITU-R was invited to study power
limitations on HAPS ground stations to facilitate sharing with space
station receivers, regulatory provisions to address deployment of HAPS
in the FS near country borders, and technical sharing criteria between
HAPS in the FS and both radio astronomy and FSS systems (taking into
account the operational environments and the requirements of FSS
systems). WRC-03 decided, after much debate, to retain the prior
limitation on notices for new FSS networks -- but only in Regions 1 and
3. WRC-03 also decided to maintain indefinitely notices for HAPS that
were received by the BR prior to 22 November 1997.

**U.S. VIEW**:

1.  The U.S. will participate in studies on the power limitations to be
    applied to HAPS ground stations to protect space station receivers.

2.  The U.S. believes, as it did at WRC-03, that the question of the
    feasibility of co-frequency operation between HAPS in the FS and the
    FSS at 47.2-47.5 GHz and 47.9-48.2 GHz has been answered in the
    affirmative. With that, there no longer is any need for Resolution
    122, the restrictions it perpetuates on FSS notices in Region 1 and
    3, or the limitless privileges it extends to HAPS notices.
    Resolution 122 should be suppressed.

**DRAFT UNITED STATES**

**PRELIMINARY VIEWS ON WRC-07**

**WRC-07 Agenda Item 1.18:** to review pfd limits in the band
17.7-19.7 GHz for satellite systems using highly inclined orbits, in
accordance with Resolution **141 (WRC‑03)**;

**ISSUE**: Suitability of Current Non-GSO FSS Power Flux-Density Limits
for Non-GSO FSS Satellites in Highly-Inclined Elliptical Orbits

**BACKGROUND**: The ITU-R has been considering the sharing aspects of
highly elliptical orbit (HEO) satellite systems in a number of contexts
and under a number of different names in recent years. HEO systems are
non-geostationary satellite orbit (non-GSO) systems, and hence are
subject to all limitations that apply to non-GSO systems in the Radio
Regulations. All HEO systems are treated as non-GSO systems by the ITU
when they are examined for regulatory compliance. WRC-97 and WRC-2000
modified the Article **21** power flux-density (pfd) limits that apply
to non-GSO FSS systems to protect terrestrial systems in the 17.7-19.7
GHz frequency band.

In Resolution 141 (WRC-03), the ITU-R has been invited to determine
whether the current pfd limits for non-GSO FSS satellite systems in
Article 21 are adequate to protect the fixed service in the 17.7 to 19.7
GHz band from non-GSO systems using highly inclined orbits, without
unduly constraining the use of these non-GSO systems. WRC-07 Agenda item
1.18 limits the review of the current non-GSO limits to non-GSO
satellite systems using highly inclined orbits, and defines these
systems as having orbit apogee altitudes greater than 18,000 kilometers
and orbital inclination between 35^o^ and 145^o^. Resolution 141 also
calls for a determination to be made as to whether there are technical
and operational measures that could be implemented by the fixed service
to mitigate interference from FSS space stations.

In preparation for WRC-03 Agenda Item 1.37 on highly-elliptical orbit
(HEO) satellites, some studies were commenced on the subject of HEO
interference into FS systems in 17.7-19.7 GHz, but no conclusions were
reached in the ITU as whether it is technically appropriate to apply the
Art. 21 pfd limits for non-GSO satellites to HEO satellites. The ITU has
begun the process of responding to Resolution 141 (WRC-03). ITU-R
Working Party 4-9S has looked at prior work, and determined that the FS
and FSS parameters used in the collected studies, along with the FS
protection criteria and methodologies for developing/assessing pfd masks
all needed further review. It has begun the process of gathering the
relevant materials from the responsible working parties in ITU-R Study
Groups 4 and 9.

Resolution 141 (WRC-03) is a follow-on item from WRC-03 Agenda Item 1.37
on HEO satellites. Unfortunately, when it used the term "highly inclined
orbit" non-GSO satellite systems instead of the term HEO in Resolution
141, WRC-03 unintentionally introduced some ambiguity into the scope of
the studies it was requesting, as the term highly-inclined orbit, by
itself, can include not only the HEO systems that were under study
pursuant to the unfinished business from WRC-03 Agenda Item 1.37, but
also some circular-orbit non-GSO systems that were never part of the
Agenda Item 1.37 studies. This ambiguity already has been noted in early
discussions within the ITU-R Working Parties responsible for and
interested in this agenda item, and could prove to be an unwelcome
distraction if the intended scope of the agenda item is not readily
clarified.

It is noteworthy that at least one HEO system has been operating in the
17.7-19.7 GHz band for years at the power levels in the applicable
portion of Article 21, and that to date, there have been no reports of
interference from the non-GSO FSS into the fixed service.

**U.S. VIEWS**:

1.  The U.S., which has looked closely at this issue over the last three
    years, believes now, as it did at WRC-03, that the non-GSO FSS pfd
    limits for the 17.7-19.3 GHz band that were included in Art. 21 at
    WRC-2000 remain adequate to protect the terrestrial services from
    non-GSO FSS satellites in highly-elliptical orbits without unduly
    constraining HEO non-GSO FSS systems.

2.  That Agenda Item 1.18 and its associated resolution, although
    ambiguously worded so as to encompass some circular-orbit non-GSO
    systems that meet the apogee altitude and orbital inclination
    criteria in *considering g)* of Resolution 141 (WRC-03), was
    intended to apply to highly-inclined (i.e., between 35º and 145º)
    non-circular-orbit non-GSO FSS satellite systems with orbital apogee
    altitudes greater than 18,000 km ***and orbital perigee altitudes
    that are less than the orbital apogee altitudes***. Consequently,
    there is no need to review the limits that apply to those non-GSO
    satellite systems using circular orbits, such as medium earth orbits
    (MEO), that satisfy both the apogee altitude criterion and the
    inclination criterion.

# 

# UNITED STATES

# DRAFT PRELIMINARY VIEWS ON WRC-07

**Agenda Item 1.19:** to consider the results of the ITU-R studies
regarding spectrum requirement for global broadband satellite systems in
order to identify possible global harmonized FSS frequency bands for the
use of Internet applications, and consider the appropriate
regulatory/technical provisions, taking also into account No. **5.516B**
of the Radio Regulations;

**ISSUE:** The purpose of this agenda item is to investigate
fixed-satellite service (FSS) frequency bands for the use by Internet
applications.

**BACKGROUND:** WRC-03 adopted this agenda item to address the use of
fixed-satellite service bands for broadband Internet applications. There
is no WRC-03 Resolution associated with this agenda item to guide and
focus ITU-R studies. WP 4A is the Study Group lead for the development
of CPM text.

**U.S. VIEWS:**

1.  The United States is of the view that any FSS frequency band can be
    used for broadband satellite systems, and that many existing and
    planned systems in a number of different FSS frequency bands are
    fully capable of providing Internet applications on a harmonized
    global basis.

2.  Given that current ground equipment is frequency agile, and
    notwithstanding the reference to No. **5.516B** in the agenda item,
    there is no need to identify a specific frequency range within the
    FSS for these applications. Any FSS allocations can be used for
    broadband Internet applications without requiring changes to the
    Radio Regulations, and without the imposition of any additional or
    particular constraints on the FSS or the use of the FSS bands.

3.  One of the FSS allocations is the bands covered by the Allotment
    Plan in Appendix 30B. The United States supports the use of the
    Appendix 30B bands for this particular application. The use of
    agenda item 1.10 and changes to the regulatory procedures and
    technical criteria in Appendix 30B to make these bands more useful
    is supported, but replanning of the allotment Plan is neither
    necessary nor supported.

**DRAFT UNITED STATES**

**PRELIMINARY VIEWS ON WRC-07**

**WRC-07 Agenda Item 1.21:** to consider the results of studies
regarding the compatibility between the radio astronomy service and the
active space services in accordance with Resolution 740 (WRC-03), in
order to review and update, if appropriate, the tables of threshold
levels used for consultation that appear in the Annex to Resolution 739
(WRC-03).

**ISSUE:**

On the basis of studies determine which of the band pairs, and
associated threshold values need to be added to the consultation
provisions of Resolution 739 (WRC-03).

# 

# BACKGROUND:

As a consequence of studies carried out in conjunction with ITU-R
Recommendation SM.1633, Resolution 739 was adopted by WRC-03 to provide
a regulatory basis for the use of consultations to provide for the
protection of the radio astronomy service in certain bands close to or
adjacent to space-to-Earth, space service allocations. The band pairs of
concern are listed in Table 1-1 of the Annex to Resolution 739 as well
as the threshold values which if exceeded by a space service
transmission would necessitate consultation.

Resolution 740, which is referenced in this agenda item, resolves: 1) to
invite the ITU-R to study the compatibility between the RAS and the
corresponding active space services listed in the Table (of the
Resolution), with a view to updating or developing ITU-R
Recommendations, if appropriate; and 2) that WRC-07 should consider the
results of the studies as identified in resolves 1, in order to review
and update, if appropriate, the tables of threshold levels for
consultation in the Annex to Resolution 739 (WRC-03).

ITU-R Task Group 1/9 was designated by CPM-06 as the lead group for
carrying out the studies referenced in resolves 1.

# U.S. VIEWS:

1.  The only band pairs and associated thresholds to be reviewed and, if
    appropriate, added to Tables 1-1 or 1-2 of Resolution 739 pursuant
    to this Agenda Item are those found in the table of Resolution 740.

2.  Any updating of Tables 1-1 or 1-2 in Resolution 739 must be based on
    the studies being carried out in TG 1/9, which could also be used as
    the basis for modifying ITU-R Recommendation SM.1633.

3.  Any studies to develop thresholds associated with band pairs from
    Resolution 740should fully consider the impact to the concerned
    active services in order to ensure that those active services are
    not unduly constrained.

4.  Changes to the consultation process provisions in Resolution 739 are
    neither appropriate nor under the scope of this agenda item.

**Recommended changes to Draft Preliminary Views from the National
Telecommunications and Information Administration's (NTIA)
Radiocommunication Conference Subcommittee (RCS):**

**WRC-07 Agenda Item 1.8:** to consider the results of studies on
technical sharing and regulatory provisions for the application of high
altitude platform stations operating in the bands 27.5-28.38 GHz and
31-31.3 GHz in response to Resolution **145 (WRC-03)**, and for high
altitude platform stations operating in the bands 47.2-47.5 GHz and
47.9-48.2 GHz in response to Resolution **122 (Rev. WRC-03)**;

**INTRODUCTION**: IWG-2 has developed a Preliminary View on the
Resolution **122 (Rev. WRC-03)** aspects of this agenda item. This
document comments only upon the Resolution **145 (WRC-03)** aspects of
the RCS Preliminary View

**DISCUSSION AND IWG-2 RECOMMENDED CHANGES TO RCS PV**

Background Section of PV: In the Background discussion of the RCS PV,
the first sentence make proper reference to WRC-97 making "a provision"
for HAPS operation in the 47 GHz band. The third sentence of this
Background section, however, makes reference to WRC-00 deciding to make
"additional allocations for HAPS" in the 28 GHz and 31 GHz bands. HAPS
systems may operate in specifically "identified" portions of Fixed
Service allocations (see RR **4.15A**). This same sentence of the RCS
PV, and the following one, also need to be modified to more accurately
reflect decisions of past WRCs on this issue. As such IWG-2 recommends
that the second and third sentences of the RCS PV be modified, and an
additional sentence be added after the third sentence, as follows:

"WRC-2000 decided to [adopt provisions]{.underline} ~~make additional
allocations~~ for [the operation of]{.underline} HAPS [on a
non-interfering/non-protected basis]{.underline} in the bands 27.5-28.35
and 31[-]{.underline}~~.~~31.3 GHz in Region 3, but did not allow
operation in the entire bands until studies could be completed to
determine how best to protect existing services in these and nearby
frequency bands. WRC-03 [further refined these provisions
by]{.underline} decid[ing]{.underline}~~ed~~ to
[limit]{.underline}~~permit~~ [HAPS]{.underline} operation [to 300 MHz
in a specified direction in each of these two bands, retaining the
requirement for HAPS to operate on a non-interfering/non-protected basis
in these 300 MHz segments, and]{.underline} ~~in the full allocated
bands by HAPS and~~ [adopt]{.underline}~~creat~~[ing]{.underline}~~ed~~
Resolution **145**, which [created the]{.underline}~~considers the
additional~~ possibility of allowing [Region 2 administrations to advise
the Radiocommunications Bureau of their intent to implement]{.underline}
HAPS [systems]{.underline}~~operations~~ [with]{.underline}in the bands
27.5-28.35 and 31-31.3 GHz ~~in region 2~~. [Administrations intending
to implement HAPS in these bands are to seek the explicit agreement of
concerned administrations in accordance with *resolves* 4 of this
Resolution.]{.underline}

**U.S. Views Section of RCS PV**: IWG-2 agrees with the "U.S. View"
section of the RCS PV, however, it is recommended to supplement this
section with the following additional U.S. View:

"The United States also supports the continued studies called for in
Resolution **145 (WRC-03)** that will demonstrate whether HAPS can
operate successfully on a non-interference/non-protected basis in the 28
GHz and 31 GHz bands, and the encapsulation of the results of these
studies, as appropriate, in ITU-R Recommendations. However, recognizing
the regulatory status of this service in these bands, the United States
does not support the specification of interference or sharing criteria
for HAPS in ITU Radio Regulations for these bands."

# Comments of IWG-2 on NTIA's RCS Draft Preliminary View on Agenda Item 1.18:

IWG-2 has prepared its own preliminary view on agenda item 1.18. In
reviewing the RCS preliminary view on this agenda item, IWG-2 found one
additional aspect on which it wishes to comment.

IWG-2 agrees with the conclusion of the RCS preliminary view that the
Article 21 pfd limits should not be changed and that HEO or HIO systems
are a sub-category of non-GSO systems and are therefore subject to the
provisions of the Radio Regulations applicable to non-GSO systems.
However, IWG-2 opposes the inclusion of the second sentence of the US
view #2: "The results of studies will be improved by considering only
2-3 HIO systems and using realistic assumptions for the characteristics
for fixed-satellite service and fixed service systems." This sentence
addresses a specific underlying assumption for studies that are ongoing
in the ITU-R and is not appropriate for text in preliminary view or
proposal language for a WRC. As an alternative to deletion of the
sentence, it could be generalized in an acceptable manner as follows:
"Studies will be improved by using realistic assumptions for the
fixed-satellite service and fixed service systems."

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

**DRAFT UNITED STATES**

**PRELIMINARY VIEWS ON WRC-07**

**WRC-07 Agenda Item 1.4:** to consider frequency-related matters for
the future development of IMT‑2000 and systems beyond IMT‑2000 taking
into account the results of ITU‑R studies in accordance with
Resolution **228 (Rev.WRC‑03)**;

**ISSUE**: Resolution **228 (Rev.WRC-03)** invited the ITU-R to further
study the technical and operational issues associated with the future
development of IMT-2000 and systems beyond IMT-2000 and to develop
reports and recommendations as required in time for WRC-07. In
particular, the Resolution invited the ITU-R to:

-   Report the results of studies on spectrum requirements and potential
    frequency ranges that take into account:

-- the evolving user needs, including the growth in demand for IMT‑2000
services;

-- the evolution of IMT‑2000 and pre-IMT‑2000 systems through advances
in technology;

-- the bands currently identified for IMT‑2000;

-- the time-frame in which spectrum would be needed;

-- the period for migration from existing to future systems;

-- the extensive use of frequencies below those identified for IMT‑2000
in No. 5.317A;

-   And to conduct studies that consider:

-- the use of frequencies below those currently identified

-- the needs of developing countries, including the use of the satellite
component of IMT-2000, for suitable coverage in these countries

-- the results of sharing and compatibility studies with services to
which the potential bands are already allocated

**BACKGROUND**: WARC-92 identified the 1885-2025 MHz and 2110-2200 MHz
bands (230 megahertz of spectrum) allocated to the mobile service for
possible use on a worldwide basis by administrations wishing to
implement IMT-2000 systems in footnote 5.388. Additionally, WRC-2000
identified the 806-960 MHz band in footnote 5.317A and the 1710-1885 MHz
and 2500-2690 MHz bands in footnote 5.384A for possible IMT-2000 use.
Each administration would decide which portions of the identified bands
to use for IMT-2000.

In Res. 228 WRC-2000 invited the ITU-R to continue studies on overall
objectives, applications and technical and operational implementation
for the future development of IMT-2000 and systems beyond. It was also
invited to study spectrum requirements and potential frequency ranges
suitable for the future development of IMT-2000 and systems beyond
IMT-2000, and in what time frame such spectrum would be needed. Res. 228
also resolved that the future development of IMT-2000 and systems beyond
are to be reviewed by WRC-07, taking into consideration the results of
ITU-R studies presented to WRC-03. Those studies were not completed in
time for WRC-03.

At WRC-03, Res. 228 was modified to invite the ITU-R to conduct and
complete in time for WRC-07, the appropriate studies of technical and
operational issues, including spectrum requirements and potential
frequency ranges suitable for those systems and to develop appropriate
Recommendations. This would enable any necessary action to be taken by
WRC-07.

The need for the studies was driven by the perception that there may be
a need for new spectrum to accommodate:

-   the increasing demand for mobile services,

-   the development of higher bandwidth technologies, and

-   the potential to use mobile services to meet universal service
    requirements

WP 8F of ITU-R is developing Reports on service types and spectrum
requirements. It is also developing a Recommendation that evaluates
suitable frequency ranges, and in what timeframe such spectrum would be
needed. WP 8F is in the process of developing the spectrum calculation
methodology for systems beyond IMT-2000 and a new Recommendation on a
spectrum calculation methodology that takes into account current
systems, 3G systems, and systems beyond 3G. The completion of this work
by WP 8F is planned for March 2006, so that the studies and
Recommendation can be presented to WRC-07 for appropriate action.

**U.S. VIEW**: The US supports conducting and participating in the
studies in WP8F to ensure that the appropriate methodology is employed;
that anticipated services are reasonable and realistic; and that the
estimate of spectrum needs is based on these reasonable
methodologies/services.

In determining the need for additional spectrum, the US must protect
existing services. The US should recognize the special needs of
developing countries.

As studies are conducted in WP8F, the US will determine if it will
support the identification of any additional bands for the deployment of
these systems.

## 

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

**DRAFT UNITED STATES**

**PRELIMINARY VIEWS ON WRC-07**

**WRC-2007 Agenda Item 1.15:** to consider a secondary allocation to the
amateur service in the frequency band 135.7-137.8 kHz.

**ISSUE**: Allocation to the amateur service the band 135.7 -- 137.8 kHz
on a Secondary basis by Footnote.

**BACKGROUND**: For more than two decades radio amateurs around the
world increasingly have been interested in experimenting with
communications at low frequencies, a part of the spectrum in which the
amateur service has not had a frequency allocation for more than 50
years. In the past ten years, more than 20 Administrations have given
domestic amateur radio allocations or have authorized experimental
amateur radio communications in the low frequency range including 73
kHz, 135.7 -- 137.8 kHz, and 160 -- 190 kHz.

Region 1. In 1997, radio amateurs in Europe were given formal authority
to operate in the LF band pursuant to the European Conference of Postal
and Telecommunications Administrations (CEPT) Recommendation 62-01 E
(Mainz 1997), which pertains to the use of the band 135.7 -- 137.8 kHz
by the amateur service. Currently, radio amateurs are active in the band
135.7 -- 137.8 kHz in more than 25 European countries. Operation in
Russia has been authorized in both the European and Asiatic parts of the
Federation. The British Royal Amateur Society (BRAS) and with the
approval of the CEPT Recommendation in Europe, France has also
authorized the use of the band 135.7 -- 137.8 kHz in St. Pierre and
Miquelon, Martinique and Guadeloupe.

Region 2. Canadian and American radio amateurs have been conducting
experimental communications in the frequency band 135.7 -- 137.8 kHz
under experimental licensees. The American Radio Relay League (ARRL) has
petitioned the Federal Communications Commission (FCC) for access to the
band (FCC RM-9404).

Region 3. New Zealand has granted an allocation to the amateur service
in this band and Australia has authorized some experimental
communication.

In the amateur radio bands at higher frequencies (above 400 MHz), the
amateur service has a history of sharing frequencies with other services
having primary allocations. As a result, radio amateurs conducting low
frequency experiments in the band 135.7 -- 137.8 kHz have taken measures
to avoid interference to the operations of the primary users of the
band. Various studies have shown that the probability of interference to
other services from amateur LF stations with an EIRP of 1 or 2 watts is
very low.

Many countries consider that there is technical and experimental merit
in a secondary allocation, subject to some constraints. This secondary
allocation may be given by adding an appropriate footnote to the Table
of Frequency Allocations.

**PRELIMINARY VIEW**: The U.S. agrees that this allocation in the band
135.7-137.8 kHz should be allocated worldwide on a secondary basis. (12
May 2004)

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

**UNITED STATES**

**DRAFT PRELIMINARY VIEWS ON WRC-07**

**WRC-07 Agenda Item 1.10:** to review the regulatory procedures and
associated technical criteria of Appendix 30B without any action on the
allotments, the existing systems or the assignments in the List of
Appendix 30B.

**ISSUE:**

Appendix 30B delineates allotments within portions of C-band and Ku-band
for each country; each allotment provides for national coverage under
specific technical conditions (e.g., maximum power densities and minimum
antenna sizes). While this plan was intended to preserve the opportunity
for all countries to obtain real benefits from use of satellite systems
in the geostationary satellite orbit (GSO), the actual number of systems
put into operation pursuant to this appendix since its original adoption
in 1988 has been quite limited.

Some aspects of the regulatory procedures and technical criteria are
outdated and serve to restrict, rather than foster, the development of
real, economical systems.

### BACKGROUND:

Since the adoption, in 1988, of Appendix 30B, satellite technologies
have advanced dramatically. And at the same time, many countries have
recognized that satellites offer great potential to facilitate access to
digital broadband services such as the Internet, thereby leaping past
antiquated technologies. Yet, only slight changes have been made to
Appendix 30B, rendering it still poorly-suited to satisfy these new
technology requirements. WRC-03 has only just begun to address the
issue. For example, full account has yet to be taken of the widespread
use of digital modulation techniques that facilitate high capacity at
substantially lower interference margins than envisaged when the
appendix was originally adopted.

WRC-03 made two notable changes to the appendix that involve the
technical criteria for analyses carried out from 5 July 2003: 1) the
interference criteria for aggregate and single entry C/I thresholds were
relaxed by 3 dB, and 2) an improved earth station off-axis gain pattern
was decided to be applied for cases requiring the additional
discrimination to resolve interference issues. Based on these decisions,
and the instructions of Resolution 146, the BR has prepared a new
reference plan reflecting these changes.

WRC-03 also recognized that additional changes to the regulatory
procedures and associated technical criteria of Appendix 30B may be
productive and thus put this item on the agenda for WRC-07. The CPM
referred this topic to WP-4A and the Special Committee (SC) for study.
At its April 2004 meeting, WP-4A, as the lead group for this item,
considered several contributions, including one from the USA, related to
this topic. WP-4A prepared a summary of the specific issues to be
studied for which contributions to its next meeting in October are
encouraged.

### U.S. Views

1.  The U.S. does not advocate any action on the allotments, the
    existing systems or the assignments in the List of Appendix 30B.

2.  The U.S. supports continued improvements to the regulatory
    procedures and associated technical criteria of Appendix 30B and is
    committed to working through the study groups and with other
    administrations toward that end.

3.  The U.S. considers that future technical criteria should be based on
    realistic parameters that reflect digital communications technology
    in use today and foreseen for the near future.

4.  The U.S. considers that sufficient flexibility should be built in to
    the regulatory procedures to permit reasonable accommodation of new
    technologies without requiring additional revisions to Appendix 30B
    post WRC-07.

5.  The U.S. intends to focus its efforts on improvements to the
    regulatory procedures and associated technical criteria for the
    Ku-band portion of Appendix 30B, as it considers this offers the
    greatest opportunity for improvements that can yield cost-effective
    access to satellite broadband services.

6.  The U.S. considers that the bands subject to Appendix 30B should be
    among those considered for the global broadband satellite systems
    serving Internet applications addressed under agenda item 1.19

**UNITED STATES**

**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:** Resolves 1 of Resolution 86 (WRC-03) reflects part of the
scope and criteria of this agenda item as determined by the
Plenipotentiary Conference in Res. 86 (Marrakesh). It specifically
states that WRC-07 should "consider any proposals which deal with
deficiencies in the advance publication, coordination and notification
procedures of the Radio Regulations for space services which have either
been identified by the Board and included in the Rules of Procedure or
which have been identified by administrations or by the Bureau as
appropriate."

In this respect certain provisions of Article 9 may not be satisfactory
for dealing with the issues of time and cost as related to their
application to the requests of satellite network coordination.

**BACKGROUND:** For a number of years the ITU has been struggling with
how to manage the extensive development of satellite networks. Such
developments have put a strain on the normal capability of the BR, which
has been responsible for the processing and examination of the Advance
Publications, Coordination Requests and Notifications of satellite
networks.

The burden was such that the 1998 Plenipotentiary Conference agreed
Resolution 88 (Minneapolis, 1998) to provide for the cost recovery of
ITU activities associated with this processing. Nevertheless, backlogs
have developed and methodologies were developed for cost recovery.
However, due to concerns raised about such methodologies, proposals for
modification are being proposed. In addition, the ITU itself is in a
budgetary crisis in which it is not certain that all of the budgeted
functions can be supported.

It appears that the difficulties that have arisen could be mitigated if
some of the responsibility of the BR were to be carried out by
Administrations. This would require modification of Article 9 of the RR.
It would give the BR staff more time to provide assistance to individual
administrations meriting such support rather than expend that same time
in support of major space users who, within their respective
administrations, should be able ably equipped to conducting coordination
without daily BR support. This would have the consequential effect of
reducing the amount of time which the BR would need to spend on
processing satellite filings.

**U.S. Views:**

1\. The US supports continued simplification of the RR procedures and is
committed to working through the study groups and with other
administrations toward that end.

2\. At this preliminary stage, it is the U.S. view that the burden on
ITU staff could potentially be reduced through modification or
replacement of portions of **Nos. 9.34-9.44** of Article 9 of the Radio
Regulations to have Administrations carry out functions currently done
by the BR. Studies are required to determine which modifications, if
any, would be appropriate. These modifications would be made under
Agenda Item 1.12 for WRC-07.

**UNITED STATES**

**DRAFT PRELIMINARY VIEWS ON WRC-07**

**WRC-07 Agenda Item 2**: to examine the revised ITU-R Recommendations
incorporated by reference in the Radio Regulations communicated by the
Radiocommunication Assembly, in accordance with Resolution **28
(Rev.WRC-03),** and to decide whether or not to update the corresponding
references in the Radio Regulations, in accordance with principles
contained in the Annex to Resolution **27 (Rev.WRC-03)**

**ISSUE**: Incorporation by Reference

**BACKGROUND**: A number of provisions of the Radio Regulations make
reference to specific ITU-R Recommendations. As these referenced ITU-R
Recommendations are updated at future meetings, it is then necessary for
later WRCs to review the corresponding Radio Regulations to see if the
references they contain should be revised to reflect the new version of
the cited ITU-R Recommendation. Otherwise, the older version of the
ITU-R Recommendation remains in effect.

Resolution **27 (Rev.WRC-03)** provides principles and procedures for
use of incorporation by reference in the Radio Regulations. WRC-03
revised this Resolution to clarify and minimize the use of this
procedure. Resolution **28 (Rev.WRC-03)** directs WRCs to review ITU-R
Recommendations incorporated by reference in the Radio Regulations that
have been revised during the elapsed study period (based on the list to
be provided by the Radiocommunication Assembly). To facilitate this
task, the Director is instructed to present to the CPM prior to the WRC
an initial list of those recommendations incorporated by reference that
have been, or are likely to be, revised in time for the WRC.

**U.S. VIEW**: WRC-07 should follow the incorporation by reference
process in Resolution **27 (Rev.WRC-03)** and Resolution **28
(Rev.WRC-03)**. It should, in accordance with Resolution **28**, review
those revised ITU-R Recommendations listed by the Director to the CPM
and communicated by the Radiocommunication Assembly to the WRC to
determine whether the updated version should be incorporated by
reference in the Radio Regulations in place of the previous version.
(5.19.04)

## 

> **II. Draft Preliminary Views formulated and approved within the
> National Telecommunications and Information Administration:**

WAC/008(08.06.04)

Mr. 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 a set of recently approved draft preliminary Executive Branch
views considering federal agency inputs toward the development of U.S.
preliminary views for WRC-2007.

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

Sincerely

> *(Original Signed April 30, 2004)*
>
> Fredrick R. Wentland
>
> Associate Administrator
>
> Office of Spectrum Management

Enclosure

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

Preparation for ITU Radiocommunication Conferences

# 

# UNITED STATES

# DRAFT PRELIMINARY VIEWS ON WRC-07

**Agenda Item 1.2:** to consider allocations and regulatory issues
related to the Earth exploration-satellite (passive) service, space
research (passive) service and the meteorological satellite service in
accordance with Resolutions **746 (WRC-03)** and **742** **(WRC-03)**;

**ISSUE:** Resolution **746** **(WRC-03)**, "Issues dealing with
allocations to science services", contains the following two issues:

1\. possible additional 100 MHz for geostationary meteorological
satellites operating in the space-to-Earth direction extending the
current 18.1-18.3 GHz geostationary meteorological satellites allocation
to 300 MHz of contiguous spectrum;

2\. consideration of the sharing conditions between the EESS (passive)
and the SRS (passive) on one hand and the fixed and mobile services on
the other hand in the band 10.6-10.68 GHz to determine appropriate
sharing criteria and to consider the inclusion of such sharing criteria
within the Radio Regulations;

and Resolution **742 (WRC-03)**, "Use of the frequency band 36-37 GHz"
deals with;

U.  consideration of sharing criteria between the passive services and
    the fixed and mobile services in the band 36-37 GHz to determine
    appropriate sharing criteria and to consider the possible inclusion
    of such sharing criteria within the Radio Regulations.

**BACKGROUND:** A primary allocation to the geostationary meteorological
satellite (space-to-Earth) exists in the band 18.1-18.3 GHz in RR No.
**5.519**. However, Resolution **746** recognizes that the bandwidth
requirements for transmission of data from high-resolution sensors on
the next generation geostationary meteorological satellites to be
launched in the time-frame 2015 to 2020 are in excess of 200 MHz.
Therefore, an extension to the existing 200 MHz allocation by 100 MHz
within the band 18-18.4 GHz is being considered. The band 18-18.4 GHz is
allocated to the fixed, fixed-satellite and mobile services. Sharing
studies are needed to determine if such an extension to the existing
allocation is feasible and have begun within the ITU-R. One fact that
could facilitate sharing in an extension band is that the number of
earth stations that would be deployed to support these meteorological
satellites will be low (on the order of five per Region). The United
States makes significant use of both the fixed and the fixed-satellite
services in the 18-18.4 GHz band and these services would need to be
protected.

The frequency band 10.6-10.68 GHz is allocated to the Earth
exploration-satellite service (EESS) (passive), radio astronomy and
space research (passive) services on a primary basis. This band is also
allocated to the mobile (except aeronautical mobile) and the fixed
services on a primary basis, taking into account RR No. **5.482**.
Passive sensing of Earth and its atmosphere has been done using this
band for many years. It is an important resource for remote sensing of
such things as rain, snow, sea state, ocean wind, and soil moisture
content and is often used in conjunction with a number of other passive
sensing bands to extract such data. The United States flies a variety of
scientific spacecraft with instruments that utilize this band. However,
the United States also makes extensive use of this band for the fixed
service. Furthermore, footnote RR **5.482** already places power and
e.i.r.p. restrictions on the fixed and mobile services. Therefore it may
be difficult to alter the current sharing conditions without placing
undue constraints on the terrestrial services in this band.

The frequency band 36-37 GHz is allocated to the Earth
exploration-satellite (passive), the space research (passive), the fixed
and the mobile services on a primary basis. Passive sensing of the Earth
and its atmosphere has been done using this band for many years. It is
an important resource for remote sensing of such things as rain rates,
snow, sea ice and clouds and is often used in conjunction with a number
of other passive sensing bands to extract such data. The United States
flies a variety of scientific and meteorological spacecraft with
instruments that utilize this band.

Resolution **742** calls for sharing studies between EESS (passive) and
the fixed and mobile services in the band 36-37 GHz to determine
appropriate sharing criteria for this band. It should be noted that the
EESS (passive) protection criteria are contained in Recommendation
ITU‑R SA.1029-2 and that Recommendation ITU‑R F.758‑2 provides
characteristics of fixed service point-to-multipoint systems operating
in the band 36-37 GHz, but does not provide information on
characteristics of fixed service point-to-point systems operating in
this band. Furthermore, the band 36-37 GHz is not available for
high-density applications in the fixed service as stipulated in RR
No. **5.547**. Due to the sensitivity and applications of passive
radiometers used in remote sensing, the EESS (passive) operating in the
band 36-37 GHz could receive interference from the emissions of systems
of these active services. There is no current use of the band in the
United States by the fixed or mobile services. However, determination of
appropriate sharing criteria should not place undue constraints on the
future use of the band by the fixed and mobile services.

**U.S. VIEW:** The United States supports the study of the possible
extension to the existing geostationary meteorological-satellite service
allocation within the 18-18.4 GHz band. If studies show that sharing is
feasible without placing undue constraints on the incumbent services,
the United States could support such an extension for high data rate
transmission from future meteorological satellites. If supported at
WRC-07, the existing footnote **5.519** could be modified to show the
geostationary meteorological-satellite service allocation within the
18-18.4 GHz band or the table of allocations could be modified to show
the allocation and footnote **5.519** would be modified to show only the
limitation of the meteorological-satellite service allocation to
geostationary orbits. Concerning the 10.6-10.68 GHz band, while the
United States supports studying the sharing conditions in this band, it
is skeptical about altering the current sharing conditions given the
existence of RR No. **5.482**. Any proposed alteration of the existing
sharing conditions would have to be examined with respect to their
possible impact on the current operation of the fixed service in this
band. Finally, the United States supports studies to determine the
appropriate sharing conditions between the EESS (passive) and the fixed
and mobile services in the band 36-37 GHz. However, implementation of
any constraints on these terrestrial services would have to be evaluated
with respect to the future operations of such services in this band.
(April 30, 2004).

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

Preparation for ITU Radiocommunication Conferences

**DRAFT PRELIMINARY VIEW FOR WRC-07**

**Agenda Item 1.3**: in accordance with Resolution **747(WRC-03),**
consider upgrading the radiolocation service to primary allocation
status in the bands 9 000-9 200 MHz and 9 300-9 500 MHz and extending by
up to 200 MHz the existing primary allocations to the Earth
exploration-satellite service (active) and the space research service
(active) in the band 9 500-9 800 MHz without placing undue constraint on
the services to which the bands are allocated;

**ISSUE**: Resolution **747(WRC-03)** further resolves that, taking into
account the results of ITU-R studies, WRC‑07 consider:

1 the upgrading of the radiolocation service to a primary allocation in
the bands 9 000-9 200 MHz and 9 300-9 500 MHz; and

2 the possible extension by up to 200 MHz of the allocation in the band
9 500-9 800 MHz to the EESS (active) and the space research service
(active),

These allocations must ensure the protection of the incumbent services
already allocated to these bands.

**BACKGROUND**: There is a need to provide contiguous spectrum in the
bands around 9 GHz for the radiolocation service allocated on a primary
basis worldwide, in order to provide adequate spectrum for new radar
systems to function. Emerging requirements for increased image
resolution and increased range accuracy necessitate wider contiguous
emission bandwidths than are currently available. Therefore, there is a
need to upgrade the status of frequency allocations to the radiolocation
service in the frequency range 9 000-9 200 MHz and 9 300-9 500 MHz in
order for existing and planned radar systems to satisfy their required
missions.

The bands 9 000-9 200 MHz and 9 300-9 500 MHz are allocated on a primary
basis to Aeronautical radionavigation and Radionavigation, respectively.
While radionavigation is recognized as a safety service as delineated in
No. **4.10** of the Radio Regulations, radiolocation services have
demonstrated compatible operations with radionavigation services in the
bands 9 000-9 200 MHz and 9 300-9 500 MHz over many years through the
use of similar system characteristics such as low-duty cycle emissions
and scanning beams as well as interference reduction techniques.
Previous and ongoing studies within the ITU-R addressing other frequency
bands indicate that sharing in the bands 9 000-9 200 MHz and
9 300-9 500 MHz between the radionavigation and radiolocation services
is likely to be feasible. It should be noted that Recommendation ITU-R
M.1313 contains the technical characteristics and protection criteria
for maritime radars in the band 9 300-9 500 MHz and that Recommendation
ITU-R M.1372 identifies interference reduction techniques which enhance
compatibility among radar systems. Further study is ongoing within the
ITU-R to confirm the compatibility between the radiolocation and
radionavigation services in these bands.

The band 9 500-9 800 MHz is allocated on a primary basis to the Earth
exploration-satellite (EESS) (active), space research (active),
radiolocation and radionavigation services, taking into account the
constraints of footnote **5.476A**. The allocation of this band to the
EESS (active) and SRS (active) was decided by WRC-97 largely based on
studies that were completed in ITU-R Joint Working Party 7-8R. In order
to satisfy global environmental monitoring requirements for improved
resolution, EESS (active) and the space research service (active)
allocations require an increase by up to 200 MHz. There are plans to
enhance synthetic aperture radars (SAR) that operate near 9.6 GHz to
improve the spatial resolution to the order of 1 meter, which would
require up to 500 MHz bandwidth. This additional bandwidth would greatly
improve the resolution of the features for global monitoring and for
environmental and land-use purposes.

Previous ITU-R studies have resulted in a number of pertinent
Recommendations. Recommendation ITU-R SA.516 indicates the general
feasibility of sharing between the EESS (active) and the radiolocation
service for active sensors. Recommendation ITU-R SA.1166 contains the
technical characteristics and protection criteria for Earth sensors
operating near 9 500 MHz. Finally, Recommendation ITU-R SA.1280
addresses the selection of active spaceborne sensor emission
characteristics to mitigate the potential for interference to
terrestrial radars operating in frequency bands 1-10 GHz. Further study
is ongoing to confirm the compatibility between EESS (active), SRS
(active) and the incumbent services in the possible extension bands
around 9 500-9 800 MHz.

**U.S. VIEW**: While there is a long history of successful co-band
operations between radiolocation and radionavigation systems near 9 GHz,
new systems may not necessarily be compatible with existing systems.
Therefore, the United States supports measurement tests and ITU-R
studies to verify the feasibility of sharing in these bands. If the
outcome of these measurements and studies is favorable, the United
States anticipates supporting the allocation upgrades for radiolocation.
However, it is the position of the United States that there would also
need to be regulatory text in the form of a footnote to protect
aeronautical radionavigation and radionavigation systems so that there
will be no constraints on ARNS/RNS use in these bands, regardless of the
outcome of the studies. Concerning the possible extension to the EES and
SRS allocations, the United States could support such an extension
provided that there is a favorable outcome from the sharing studies and
that the incumbent services are protected. Some regulatory text in the
form of one or more applicable footnotes may be necessary to ensure such
protection. (April 9, 2004)

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

Preparation for ITU Radiocommunication Conferences

# 

# UNITED STATES

# DRAFT PRELIMINARY VIEWS ON WRC-07

**AGENDA ITEM 1.4:** to consider frequency-related matters for the
future development of IMT-2000 and systems beyond IMT-2000 taking into
account the results of ITU-R studies in accordance with Resolution **228
(Rev.WRC-03)**;

**ISSUE:** The actions associated with this agenda item include;
additional applications for advanced wireless services beyond those
identified for IMT-2000 systems, the spectrum requirements associated
with these requirements, and candidate bands where these requirements
may be satisfied. The primary issue from these actions will be the
availability of the required spectrum and the impact to incumbent users.

**BACKGROUND:** WRC-2000 and prior WRCs, identified 749 MHz of spectrum
for terrestrial IMT-2000. During the period between WRC-2000 and WRC-03,
the ITU continued its work on the radio interface technology standards
and future market requirements. WRC-03 did not identify new spectrum,
however there was an expectation at the conference that new spectrum
would be required for systems beyond IMT-2000. WP8F is studying new
market and service requirements and additional spectrum needs. Upon
completion of these studies, WP8F will select candidate bands and
conduct sharing studies with existing services.

**U.S. VIEW:** Before an agreement can be reached on additional bands to
be identified for systems beyond IMT-2000, the bandwidth requirements
must be fully agreed in the ITU-R and the bands chosen must be available
for use. The bandwidth requirements must consider, in as realistic
fashion as possible, the expected future applications and demand for
these applications. In addition, the availability of existing bands for
IMT-2000 and beyond must be included. The bands identified for these
future applications must also be available for use globally and/or
regionally. Available for use implies that sharing can be accomplished
with existing users or the incumbents can be accommodated in an
equitable fashion. For systems beyond IMT-2000, proponents must
demonstrate that the spectrum already allocated for their use is
insufficient and that *X* amount of spectrum is required to meet their
future requirement for *Y* years. While a global solution is preferred,
regional solutions are appropriate for resolution at an ITU level.
National solutions should not drive the work in identifying these bands.
(April 30, 2004)

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

Preparation for ITU Radiocommunication Conferences

# 

# UNITED STATES

# DRAFT PRELIMINARY VIEWS ON WRC-07

**Agenda Item 1.5:** to consider spectrum requirements and possible
additional spectrum allocations for aeronautical telecommand and high
bit-rate aeronautical telemetry;

**ISSUE**: Obtaining sufficient spectrum to satisfy wideband
aeronautical mobile telemetry requirements and associated telecommand
above 3 GHz, possible sharing with existing services, and continued
protection of incumbent services.

**BACKGROUND**: This agenda item has its origins in efforts undertaken
by the Space Industry prior to WRC-97. The issue was pursued by the
United States, CITEL and other regions at WRC-03 and placed on the
agenda for WRC-07. This agenda item seeks to address a large and growing
shortfall in spectrum necessary to conduct aeronautical telemetry. The
shortfall is due to rapidly increasing telemetry data rates associated
with the testing of new technologies. The shortfall is exacerbated by
the loss of telemetry spectrum diverted to other than telemetry
applications. Without additional spectrum, aeronautical development will
be subject to major delays, escalating costs, and the impairment of
global competitiveness of the aerospace industry (including equipment
manufacturers, civilian space programs and test ranges, airlines, and
passengers). In addition, the benefits of new worldwide telemetry
spectrum will greatly aid most other countries and the international
aeronautical community, as Administrations continue to support their
national airlines and some administrations initiate their own space
programs. Existing international allocations used for aeronautical
telemetry will need to remain available without additional constraints
for current applications.

**U.S. VIEW**: The United States supports additional spectrum
allocations for aeronautical telemetry. Once the ITU-R completes its
studies, the United States can make a recommendation regarding the
methods by which the agenda item can be best satisfied. (April 30, 2004)

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

Preparation for ITU Radiocommunication Conferences

# 

# UNITED STATES

# DRAFT PRELIMINARY VIEWS ON WRC-07

**Agenda Item 1.7:** to consider the results of ITU-R studies regarding
sharing between the mobile-satellite service and the space research
service (passive) in the band 1 668 -- 1 668.4 MHz, and between the
mobile-satellite service and the mobile service in the band 1 668.4 --
1 675 MHz in accordance with Resolution **744** **(WRC‑03)**

**ISSUE:** Resolution **744** **(WRC-03)**, deals with sharing between
the mobile satellite service (MSS) (Earth-to-space) and the
space-research (passive) service in the band 1 668 -- 1 668.4 MHz and
between the MSS (Earth-to-space) and the fixed and mobile services in
the band 1 668.4 -- 1 675 MHz.

**BACKGROUND:** At WRC-03, a new global allocation was made to the MSS
(Earth-to-space) in the band 1 668 -- 1 675 MHz and a global allocation
to the MSS (space-to-Earth) in the band 1 518 -- 1 525 MHz. MSS
interests provided support for this agenda item. In the United States,
the band 1 668 -- 1 668.4 MHz is allocated to the space research
(passive) and radio astronomy services (RAS) and the band 1 668.4-1 670
MHz is allocated to meteorological aids (MetAids) (radiosonde) and radio
astronomy, both on a primary basis. The band 1 670 -- 1 675 MHz is
currently planned for use in the United States for the fixed and mobile
services, and the MSS shall not claim protection from fixed and mobile
stations operating within the United States. One Region 2 Administration
also expressed interest in new allocations for the MSS at the WRC and
thus there may be cross-border issues, involving coordination zones that
need to be resolved.

**U.S. VIEW:**

**1.** The United States supports the completion of studies
demonstrating how: a) Radio astronomy and Space Research (passive)
services, and b) Radio astronomy stations and MetAids earth stations can
be protected from interference from mobile earth stations, in the bands
1 668 -- 1 668.4 MHz and 1 668.4-1 670 MHz, respectively. Preliminary
studies within the ITU-R show that co-frequency sharing between RAS
stations and mobile earth stations (MES) is feasible, e.g. by employing
coordination zones of radii on the order of 300 km, under worst case
scenarios. To date, these studies considered only terrestrial MES; the
airborne case was not considered. Interference by MES operating in the
1 670-1 675 MHz band can be prevented by much smaller coordination
radii, on the order of 50 km.

U.  The United States supports the completion of sharing studies between
    the mobile service and MSS in the band 1 668.4 -- 1 675 MHz,
    recognizing that stations in the MSS shall not claim protection from
    fixed and mobile stations operating in the United States, as stated
    in the *resolves* of Resolution **744**. (April 30, 2004).

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

Preparation for ITU Radiocommunication Conferences

# 

# UNITED STATES

# DRAFT PRELIMINARY VIEWS ON WRC-07

**Agenda Item 1.8**: to consider the results of ITU-R studies on
technical sharing and regulatory provisions for the application of high
altitude platform stations operating in the bands 27.5-28.35 GHz and
31‑31.3 GHz in response to Resolution **145 (WRC‑03),** and for high
altitude platform stations operating in the bands 47.2-47.5 GHz and
47.9-48.2 GHz in response to Resolution **122 (Rev.WRC‑03);**

**ISSUE**: Resolution **145** invites WRC-07 to review and consider
appropriate refinement of the regulatory provisions for the use of HAPS
within the bands 27.5-28.35 and 31-31.3 GHz. The resolution limits the
use of HAPS to 300 MHz in each band, and such use shall not cause
harmful interference to, nor claim protection from, other stations of
services operating in accordance with the Table of Frequency Allocations
of Article **5**, and, further, that the development of these other
services shall proceed without constraints by HAPS operating pursuant to
this resolution.

Resolution **122** deals with the use of the bands 47.2-47.5 GHz and
47.9-48.2 GHz by high altitude platform stations (HAPS) in the fixed
service and by systems and networks in the fixed-satellite service
(FSS).

**BACKGROUND**: WRC-97 first made a provision for the operation of HAPS,
also known as stratospheric repeaters, within a 2 X 300 MHz portion of
the fixed-service allocation in the bands 47.2-47.5 GHz and 47.9-48.2
GHz. During WRC-2000, several countries expressed a need for a lower
frequency band for HAPS due to excessive rain attenuation that occurs at
47 GHz. WRC-2000 decided to make additional allocations for HAPS in the
bands 27.5-28.35 and 31-31.3 GHz in Region 3, but did not allow
operation in the entire bands until studies could be completed to
determine how best to protect existing services in these and nearby
frequency bands. WRC-03 decided to permit operation in the full
allocated bands by HAPS and created Resolution **145**, which considers
the additional possibility of allowing HAPS operations in the bands
27.5-28.35 and 31-31.3 GHz in Region 2. Additionally, WRC-03 specified
certain regulatory provisions for the use of HAPS in these bands to
protect existing and nearby allocated services.

**U.S. VIEW**: The existing HAPS ground station power density limits
described in No. **5.543A** adequately protect passive satellite
services operating in 31.3-31.8 GHz, yet provide sufficient power for
operation of ground-to-HAPS links. The United States anticipates
supporting no change to the existing No. **5.543A**.

The United States supports studies on the power limitation to be applied
to HAPS ground stations to protect space station receivers in the band
47.2-47.5 GHz and 47.9-48.2 GHz. (April 30, 2004)

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

Preparation for ITU Radiocommunication Conferences

# 

# UNITED STATES

# DRAFT PRELIMINARY VIEWS ON 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:** This agenda item deals with the development of sharing
criteria and regulatory provisions to facilitate use of the band by
satellite and terrestrial services without placing undue constraints on
any services allocated in the band. To protect U.S. terrestrial
services, there may need to be studies to ensure Region 1 and 3 space
service uses does not cause interference.

**BACKGROUND:** One of the bands identified for IMT-2000 at WRC-2000 was
the 2 500-2 690 MHz band. In the United States this band has been
identified for advanced terrestrial wireless services (FCC Report and
Order 03-269). Internationally, in addition to the band being identified
for IMT-2000 use, parts of the band are allocated for the broadcast
satellite service (BSS) and the mobile satellite services (MSS). Within
WP8F, there have been preliminary attempts at defining a band plan for
terrestrial use of this band and it is expected this would continue. The
sharing issues between NGSO BSS (Sound) and terrestrial services have
been addressed by WRC-03 and it is anticipated that they will not be
reopened under this agenda item.

**U.S. VIEW:** In the United States this band is designated for advanced
terrestrial wireless applications and there is a strong possibility that
this band could be used to meet future IMT-2000 requirements, thereby
relieving pressure on the identification of new bands. (April 30, 2004)

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

Preparation for ITU Radiocommunication Conferences

# 

# UNITED STATES

# PRELIMINARY VIEWS ON WRC-07

**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 31hanneling arrangements are in Appendix **17**, taking
account of the impact of new modulation techniques, adaptive control
techniques and the spectrum requirements for HF broadcasting;

**ISSUE:** There are three areas to be addressed:

a.  to consider frequency assignments for frequency adaptive systems in
    frequency bands allocated for fixed/mobile operation per Resolution
    **729**,

b.  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 per Resolution **351**,

c.  to consider identification of additional spectrum for HF
    broadcasting between 4-10 MHz per Resolution **544**. In particular
    focus has been given to the following bands:

> 4 500-4 650 kHz
>
> 5 060-5 250 kHz
>
> 5 840-5 900 kHz
>
> 7 350-7 650 kHz
>
> 9 290-9 400 kHz
>
> 9 900-9 940 kHz,

**BACKGROUND:** There are three separate issues to be addressed within
agenda item 1.13. Each Resolution, although related due to possible
impact to systems, will be studied in a separate ITU-R WP as the primary
lead. The commonality between these items comes in the form of
interested ITU-R WPs:

a.  Resolution **729** is a hold-over from WRC-97 and has not been
    successfully completed at this time. The lead group is WP 9C.

b.  Resolution **351** from WRC-03 and the studies for a technology or
    interoperable technologies have not been completed. The lead group
    is WP 8B.

c.  Resolution **544** from WRC-03, where it was agreed that no
    allocation would be considered for WRC-03. It was put to WRC-07 to
    resolve this issue on additional HF broadcasting spectrum. This was
    a very difficult issue at WRC-03 and in past WRCs where it has been
    discussed. The lead group is WP 6E.

**U.S. VIEW:** These issues, although related should still be addressed
separately in the groups assigned primary responsibility with
cooperation from other groups achieved through liaison statements and
cross participation from administration experts that attend the
contributing groups for each issue.

> **Resolution 729** -- Before this Resolution can be resolved,
> development ITU-R Recommendations on characteristics for HF Frequency
> Adaptive systems is needed. In addition, review of the utilization of
> current and future fixed HF operations is required. Once this has been
> accomplished within WP 9C, then the feasibility and need of modifying
> the HF channel plans to accommodate HF adaptive systems can be
> investigated. Every attempt should be made to accomplish these tasks
> prior to WRC-07 to keep this resolution from being "rolled-over" to
> the next conference. Also this resolution is not limited to the 4-10
> MHz band, and could impact all fixed HF channel plans (3-30 MHz).
>
> **Resolution 351** -- Given the vital nature of the safety systems in
> Appendix **17**, that a thorough review of the digital techniques for
> the HF/MF bands must be accomplished before any changes are made.
> Recommendations that detail the characteristics of these digital
> systems and a review of Appendix **17** operations must be
> accomplished to fully determine the impact of any changes. Every
> attempt should be made to accomplish these tasks prior to WRC-07 to
> keep this resolution from being "rolled-over" to the next conference.
> This resolution is not limited to the 4-10 MHz band, and could impact
> all of Appendix **17**.
>
> **Resolution 544** -- This contentious resolution dealing with the
> 4-10 MHz band must be considered carefully, taking into account impact
> on existing services after a careful review of broadcasting service
> requirements. Initial investigation shows that the allocation of all
> of the spectrum identified as "preferred" bands is problematic for the
> United States given that vital government systems operate in all these
> bands. In a proposal to WRC-03 the United States limited allocations
> to 250 kHz of spectrum for the broadcasters. The United States is
> investigating the current requirement that is needed to meet
> broadcasting needs.

The United States agrees with the need for a thorough study of the
consequences of the current situation, augmented with projections of
future broadcasting HF use. There should be a clear set of findings from
this study of the maximum amount of spectrum desired, as well as what
can be accomplished with lesser amounts of additional allocated
broadcasting spectrum, including the case where no new spectrum for
broadcasting is added. (April 30, 2004)

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

Preparation for ITU Radiocommunication Conferences

# 

# UNITED STATES

# DRAFT PRELIMINARY VIEWS ON WRC-07

**Agenda Item 1.17:** to consider the results of ITU-R studies on
compatibility between the fixed-satellite service and other services
around 1.4 GHz, in accordance with Resolution **745** **(WRC-03)**;

**ISSUE:** Resolution **745 (WRC-03)**, deals with the protection of
existing services in all Regions from non-geostationary-satellite
feederlinks for mobile-satellite service links below 1 GHz operating in
the fixed-satellite service and using the frequency bands around 1.4 GHz
on a secondary basis.

**BACKGROUND:** At WRC-03, the Conference decided to make the bands
1 390-1 392 MHz and 1 430-1 432 MHz available for the fixed-satellite
service (FSS) on a secondary basis for feeder links in the (Earth-to
space) and (space-to-Earth) directions, respectively, for non-GSO
satellite systems in the MSS with service links operating below 1 GHz,
and subject to Resolution **745** as follows:

> **1** that the additional allocations for the FSS on a secondary basis
> in the bands 1 390-1 392 MHz and 1 430-1 432 MHz for feeder links in
> the (Earth-to space) and (space-to-Earth) directions, respectively,
> for non‑GSO satellite systems in the MSS with service links operating
> below 1 GHz, shall not be used until the completion of ITU‑R studies
> on all identified compatibility issues as shown in Annex 1 to this
> Resolution and the results of these studies shall be reported to
> WRC‑07 and the decisions should be taken by WRC‑07 accordingly;
>
> **2** to recommend that decisions taken by WRC‑07, including any
> provisions for the protection of other services to which the bands in
> *resolves* 1 are allocated, and of passive services in the adjacent
> band, apply to all non‑GSO FSS systems in these bands filed to the
> Bureau after 5 July 2003,

The band 1 350-1 400 MHz is allocated on a primary basis to the
radiolocation, fixed and mobile services in Region 1 and to the
radiolocation service in Regions 2 and 3, and the footnotes Nos.
**5.149**, **5.338** and **5.339** also apply to this band. The band
1 400-1 427 MHz is allocated to the Earth exploration-satellite service
(EESS) (passive), radio astronomy and space research (passive) services
on a primary basis in all Regions and footnote No. **5.340** also
applies to this band. The band 1 427-1 429 MHz is allocated in all
Regions to the space operation (Earth-to-space), fixed and mobile
(except aeronautical mobile) services on a primary basis. The band
1 429-1 452 MHz is allocated on a primary basis to the fixed service in
all Regions, to the mobile service (except aeronautical mobile) in
Region 1 and to the mobile service in Regions 2 and 3. It should also be
noted that footnote No. **5.341** also applies to the band
1 400-1 452 MHz and that footnote No. **5.342** also applies to the band
1 429-1 452 MHz in Region 1. As can be seen from this discussion of the
existing allocations prior to WRC-03, additional allocations in the
frequency region are quite complicated as many other services are
potentially impacted.

The CPM‑02 Report indicated that there were significant technical
challenges to be overcome in some areas if existing services,
particularly passive services, were to be protected from harmful
interference from the operation of feeder links around 1.4 GHz. The
report also indicated that studies in ITU‑R were incomplete for the
radio astronomy, EESS (passive), space research, aeronautical mobile
(aeronautical mobile telemetry (AMT)) and radiolocation services. This
posed some difficulties for WRC-03 and the Conference decided to make
the secondary allocation for the MSS feederlinks subject to completion
of this work.

Studies are on-going in various ITU-R groups to complete this technical
work and to determine the technical and operational means of enabling
the use of the MSS feederlink allocations while at the same time
protecting the existing services. While the amount of work necessary is
substantial, the United States believes that these secondary allocations
around 1.4 GHz to the fixed-satellite service (FSS) for feeder links for
non-GSO satellite systems in the MSS with service links below 1 GHz will
support the development of new services on a global basis and be very
beneficial to many administrations, especially those in developing
countries.

**U.S. VIEW:** The United States supports the completion of studies, and
testing and demonstrations to validate such studies, on operational and
technical means to facilitate sharing around 1.4 GHz, including the
protection of the passive services in the band 1 400-1 427 MHz from
unwanted emissions. Upon the successful completion of these studies,
tests and demonstrations, the United States supports implementation of
appropriate provisions in the Radio Regulations to protect existing
services and the use of the bands 1 390-1 392 MHz and 1 430-1 432 MHz
for non-geostationary-satellite feederlinks for mobile-satellite service
links below 1 GHz operating in the fixed-satellite service (April 9,
2004).

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

Preparation for ITU Radiocommunication Conferences

# 

# UNITED STATES

# DRAFT PRELIMINARY VIEWS ON WRC-07

**Agenda Item 1.18:** to review the pfd limits in the band 17.7-19.7 GHz
for satellite systems using highly inclined orbits, in accordance with
Resolution **141 (WRC-03)**;

**ISSUES:**

1.  Whether the current pfd limits in Article **21** for non-GSO systems
    in the FSS are adequate to protect the fixed service in the
    17.7-19.7 GHz band from non-geostationary systems using
    highly-inclined orbits (HIOs) having an apogee altitude greater than
    18000 km and an orbital inclination between 35 and 145 without
    unduly constraining the use of these non-GSO FSS systems.

2.  Whether there are technical and operational measures in the band
    17.7-19.7 GHz that could be implemented in the fixed service to
    mitigate interference from FSS space stations in HIO.

3.  As a consequence of this agenda item, whether HIOs should be
    categorized as special type of non-GSO distinct from other non-GSOs
    such as low or medium earth orbit systems.

**BACKGROUND:** The ITU-R has been considering sharing aspects for
non-GSO systems using HIOs, including systems in highly elliptical orbit
(HEO), for a number of years. Several categories of orbits are
encompassed within the term "highly-inclined", including "highly
elliptical". These are all non-geostationary satellite systems and need
to be treated as such. WRC-95 adopted provisional limits on the pfd
produced at the surface of the Earth by non-GSO satellites operating in
the FSS (space-to-Earth) in the band 17.7-19.3 GHz in order to protect
terrestrial services. These limits were revised at WRC-97 and WRC-2000.
WRC-03 determined that no changes were needed to the pfd limits and
associated provisions in Section **V** of Article **21** that were
finalized at WRC-2000 for all non-GSO FSS systems in the 17.7-19.7 GHz.
WRC-03 adopted Resolution **141** **(WRC-03)**, which invites the ITU-R
to conduct studies to determine whether the current pfd limits in
Article **21** for non-GSO systems in the FSS are adequate to protect
the fixed service in the 17.7-19.7 GHz band from non-geostationary
systems using HIOs, of the orbital characteristics as stated in
considering g) of Resolution **141**, and whether there are technical
and operational measures that could be implemented by the fixed service
to mitigate interference from FSS space stations in HIO.

Studies previously performed by ITU-R on the sharing between
non-homogeneous non‑GSO satellite systems noted that sharing between
non-GSO systems was self-limiting and assumed a maximum effective number
of 3.5 systems for co-coverage, co‑frequency, non‑GSO systems, including
HIO systems. It is noteworthy that at least one HIO system has been
operating in the 17.7-19.7 GHz band for several years at the power
levels in the applicable portion of Article **21**, and that to date,
there have been no reports of interference from the non-GSO FSS into the
fixed service.

**U.S. VIEW:**

1.  The United States continues to support no change to the current
    limits and associated provisions in Section V of Article **21** for
    all non-GSO FSS systems in the 17.7-19.7 GHz frequency bands.

2.  ITU-R studies on sharing between non-GSO systems using HIOs and FS
    networks should continue. The results of studies will be improved by
    considering only 2-3 HIO systems and using realistic assumptions for
    the characteristics for fixed satellite service and fixed service
    systems.

3.  Satellite networks using HIOs should continue to be considered as
    non-GSOs and have the same regulatory standing as other types of
    non-GSOs such as those in low and medium earth orbits. There is no
    need to modify the Radio Regulations in a way that separates
    HIO-type non-GSO operations from other non-GSO systems (April 30,
    2004).

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

Preparation for ITU Radiocommunication Conferences

# 

# UNITED STATES

# PRELIMINARY VIEWS ON WRC-07

**Agenda Item 1.19:** to consider the results of the ITU-R studies
regarding spectrum requirement for global broadband satellite systems in
order to identify possible global harmonized FSS frequency bands for the
use of Internet applications, and consider the appropriate
regulatory/technical provisions, taking also into account No. **5.516B**
of the Radio Regulations;

**ISSUE:** The purpose of this agenda item is to identify fixed
satellite service (FSS) frequency bands for the use of internet
applications, while keeping in mind the newly identified high density
fixed satellite service (HDFSS) bands **(No. 5.516B)** and consider the
appropriate regulatory and technical provisions.

**BACKGROUND:** WRC-03 adopted this agenda item to identify fixed
satellite service bands for the use of broadband internet applications.
It is not exactly clear what the objective is for this agenda item, but
No. **5.516B** does reference Resolution **143**, which provides
guidelines for the implementation of high-density applications in the
fixed-satellite service in frequency band identified for this service.
WP 4A is the Study Group lead, and the intent of the agenda item will
become clear in the near future.

**U.S. VIEW:**

**1.** The United States supports the use of the underutilized FSS
Allotment Band Plan (AP30B) for this particular application. The use of
agenda item 1.10 and changes to the technical characteristics of the
Plan, to make these bands more useful is supported, but replanning of
the allotment plan is not supported.

U.  The United States supports the use of the HDFSS bands (see RR No.
    **5.516B** and Resolution **143**) for broadband internet access
    applications. Taking this into account the appropriate regulatory
    provisions in the Radio Regulations are already in-place and there
    is no need for additional Radio Regulation modification. (April 9,
    2004)

# 

Mr. 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 U.S.
Preliminary Views for WRC-2007. The enclosed preliminary view addresses
WRC-07 agenda item 1.21.

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

Sincerely

*(Original Signed May 7, 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**

**Agenda Item 1.21:** to consider the results of studies, regarding the
compatibility between the radio astronomy service and the active space
services in accordance with Resolution **740 (WRC--03)**, in order to
review and update, if appropriate, the tables of threshold levels used
for consultation that appear in the Annex to Resolution
**739 (WRC--03)**;

**ISSUE:** Taking into account the results of the compatibility studies,
including the impact on the active and passive services concerned, in
the band pairs contained in the Table to Resolution **740**, should
WRC-07 include any or all of the band pairs in Annex 1 to Resolution
**739**? If so, what are the appropriate threshold levels for
consultation?

**BACKGROUND:** In preparation for WRC-03, Task Group 1/7 conducted
studies that led to the adoption of Recommendation ITU--R SM.1633, which
contains over 20 annexes that, using the methodology contained in the
Recommendation, assess the compatibility of various band pairs between
the radio astronomy service and space services. Not all studies in the
annexes are complete. On the basis of Recommendation SM.1633 and
associated studies, WRC-03 adopted Resolutions **739** and **740**.

Resolution **739** contains guidance to administrations operating space
and radio astronomy stations in the band pairs contained in Tables 1-1
and 1-2, in order to come to acceptable solutions regarding space
station unwanted emissions at a radio astronomy station. A consultation
process is included.

Resolution **740** calls for the completion of studies for the band
pairs indicated in its associated band pair Table. Comprehensive studies
are needed to determine whether any of the band pairs from Resolution
**740** should be added to the tables in Resolution **739**, and, if so,
\[to determine\] the impact on all the concerned active and passive
services and the appropriate threshold levels for consultation.

**U.S. VIEW:** Satisfactory studies need to be completed before a
determination is made regarding adding any of pairs contained in
Resolution **740** to the Table in Resolution **739**. The studies must
identify the appropriate threshold levels for consultation and the
impact on the concerned active and passive radio services.

WAC/010(08.06.04)

Mr. 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 four additional approved Executive Branch preliminary views
considering federal agency inputs toward the development of U.S.
Preliminary Views for WRC-2007. These preliminary views address WRC-2007
agenda items 1.6, 1.14, 1.15, 1.16.

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

> Sincerely

*(Original Signed May 28, 2004)*

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

Enclosure

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

Preparation for ITU Radiocommunication Conferences

**UNITED STATES**

**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)**;

**ISSUES**: This agenda item encompasses three distinct efforts:

> 1\) to determine whether additional allocations for aeronautical
> mobile (route) service (AM(R)S) are necessary: a) First consider
> adding AM(R)S allocations to existing aeronautical bands; and b) If
> step a is not sufficient, consider adding AM(R)S allocations to bands
> that are not currently used by aviation,
>
> 2\) specifically consider how to accommodate the requirements for
> aeronautical systems in the band 5 091-5 150 MHz,
>
> 3\) to examine the possibility of broadening the services and
> applications of the use of current satellite frequency allocations in
> order to allow the expansion of ICAO CNS/ATM systems that can also
> support other non‑aeronautical telecommunication services.

**BACKGROUND**: The first of the three efforts contained in this agenda
item addresses the current situation of existing AM(R)S bands nearing
saturation in core Europe and the United States. In addition, many of
the evolving navigation and surveillance applications may not meet the
ITU-defined use of propagation property of waves required in order to
operate in a radionavigation band. WRC-03 provided a good example of the
latter issue, with the agenda including addition of a limited AM(R)S
allocation to the 108-117.975 MHz band to accommodate International
Civil Aviation Organization (ICAO) standard navigation and surveillance
systems.

The second effort involves studies to consider how to accommodate the
requirements for aeronautical systems in the band 5 091-5 150 MHz.
Though this might be considered a subset of effort 1 as most proposed
applications would fit under AM(R)S, the item is slightly 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.

The third effort was proposed by a number of administrations with the
goal of allowing them to modernize their air traffic control systems
without requiring the need for extensive ground facilities. Studies are
expected to focus on utilization of the ICAO Global Navigation Satellite
System (GNSS) to improve navigation and timing services, and the
exploration of using available satellite communications where safety
objectives can be assured.

**U.S. VIEW**: Though studies have not been completed that quantify
aviation need for additional AM(R)S spectrum, current aviation
communication bands are severely congested. In addition, recent
experience has shown that evolving technology for navigation and
surveillance may necessitate allocations that are more encompassing than
simply aeronautical radionavigation service (ARNS). As a result, the
United States anticipates supporting the addition of AM(R)S allocations
in some frequency bands depending on the results of ITU-R studies.

Regarding the second effort, AM(R)S applications in the 5 091-5 150 MHz
band will be included in the effort 1 response. Based on these studies,
the United States expects that a portion of the band will be reserved
for the fixed service limited to aeronautical applications at airports.

Regarding the third effort, the United States expects to support the use
of the Global Positioning System (GPS) as a constituent element of the
GNSS. (May 27, 2004).

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

Preparation for ITU Radiocommunication Conferences

**UNITED STATES**

**DRAFT PRELIMINARY VIEWS ON WRC-07**

**Agenda Item 1.14**: to review the operational procedures and
requirements of the Global Maritime Distress and Safety System (GMDSS)
and other related provisions of the Radio Regulations, taking into
account **Resolutions 331 (Rev.WRC‑03) and 342 (Rev.WRC‑2000)** and the
continued transition to the GMDSS, the experience since its
introduction, and the needs of all classes of ships;

**ISSUE:** Per Resolution **331,** the transition to the GMDSS has not
been completed by a large number of administrations**.** This transition
requires the eventual modification of Appendix **13**, to include its
possible deletion, and replacement by a suitable recommendation covering
vessels subject to the radio regulations that are not required to be
GMDSS equipped. However, until the transition is complete, provisions of
Appendix **13** are still applicable and need to be retained, and
possibly rewritten for non-SOLAS vessels that will not be under the
purview the regulations of GMDSS. Also, as GMDSS is becoming the new
worldwide distress alerting system there are applicable lessons learned
and changes to incorporate in Chapter VII, IX, and other portions of the
Radio Regulations. Resolution **342** calls for the review of Appendix
**18**, with the goal of accommodating new VHF technology in the 156-174
MHz band. WRC-2003 modified Appendix **18**, including the addition of
note *o)*, to permit the possible use, on a voluntary basis, of various
channels or bands created by the conversion of some duplex channels to
simplex channels, for the initial testing and the possible future
introduction of new technologies. The challenge before WP 8B is to
identify world wide interoperable digital technology that is adaptable
to the maritime mobile service. ITU-R WP 8B plans to evaluate the future
uses of the currently designated Public Correspondence VHF Channels for
other maritime related use, in view of the worldwide decline of VHF
public correspondence services.

**Background**: The reasons for this agenda item are to ensure that
GMDSS requirements and procedures are current, administrations continue
the transition from legacy non-GMDSS distress and safety systems, and
ensure that the International Radio Regulations continue to accommodate
the needs of those that have not made the transition to the GMDSS. This
agenda item will continue to provide worldwide maritime safety system
coordination to promote Safety-of-Life at sea in conjunction with
International Maritime Organization (IMO) circulars and directives. This
agenda item also promotes the efficient use of the VHF maritime band and
accommodates new VHF technology in this band. Many administrations and
regional groups will support changes to Appendix **18**.

**U.S. VIEW:** The United States believes that the distress and safety
communications, non-GMDSS, should be revised to accommodate
interoperability with GMDSS. In particular, Chapter VII of the Radio
Regulations should be revised. This interoperability is required to
maintain Safety-of-Life at sea until the maritime community has fully
transitioned to the GMDSS standard. In accordance with IMO
recommendations, GMDSS ships continue to keep continuous guard on VHF
channel 16 (156.8 MHz) with a view to maintaining communications between
SOLAS and Non-SOLAS ships. The United States maintains that all vessels
are encouraged to make use of the GMDSS as soon as possible. The IMO has
authorized the discontinuance of a 2182 KHz guard for SOLAS vessels. The
United States, in recognition of its continuing domestic requirements
regarding non SOLAS vessels outside of VHF range, will maintain a 2182
kHz guard for the foreseeable future.

With regard to the use of new technologies for the maritime mobile
service in the band 156-174 MHz and the consequential revision of
Appendix **18** to reflect new technologies, the United States supports
and is implementing port and coastal systems in accordance with
Recommendation ITU-R M.1371-1 for Automatic Identification System (AIS).
The further introduction of digital systems into this band should be
based on adopting suitably modified land mobile technology into a
worldwide interoperable standard. Appendix **18** should also be
modified to reflect the current diminished demand for public
correspondence coast stations. (May 27, 2004)

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

Preparation for ITU Radiocommunication Conferences

**UNITED STATES**

**DRAFT PRELIMINARY VIEWS ON WRC-07**

**Agenda Item 1.15:** to consider a secondary allocation to the amateur
service in the frequency band 135.7‑137.8 kHz;

**ISSUE:** Determine the impact of this proposed secondary allocation on
the fixed and mobile primary services. Low Frequency (LF) propagation
must be considered carefully due to potential worldwide propagation
characteristics. Amateur emissions from this possible secondary
allocation must be assessed for compatibility of services to the fixed
and maritime mobile services.

**BACKGROUND:** Amateurs want to continue to perform experimental
communications in the 135.7‑137.8 kHz band segment. This spectrum is
currently allocated to the fixed and maritime mobile services
internationally and domestically. One Region 1 administration currently
allows amateurs to operate in this frequency range limiting EIRP to 1
watt. Also, many other administrations have permitted experimental
operation on a case-by-case basis.

**U.S. VIEW:** The United States could support a secondary allocation to
the amateur service in the band 135.7-137.8 MHz depending on the results
of ITU-R studies. ITU-R studies should include an assessment of the
impact of an amateur secondary allocation to currently allocated
services and a determination of appropriate protection criteria for the
fixed and mobile maritime services. (May 27, 2004)

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

Preparation for ITU Radiocommunication Conferences

**UNITED STATES**

**DRAFT PRELIMINARY VIEWS ON WRC-07**

**Agenda Item** **1.16:** to consider the regulatory and operational
provisions for Maritime Mobile Service Identities (MMSIs) for equipment
other than shipborne mobile equipment, taking into account
**Resolutions 344 (Rev.WRC‑03)** and **353 (WRC‑03)**;

**ISSUE:** The expansion of MMSIs is proposed for effective maritime
Search and Rescue (SAR) operations and enhancements of the maritime
navigation systems. SAR aircraft using Digital Selective Calling (DSC)
require assignment of MMSIs to enable effective communications with
ships during emergency communications. Also, the assignment of MMSIs to
aids-to-navigation will increase maritime navigational safety. The MMSIs
for equipment other than shipborne mobile equipment must be unique to
prevent confusion between vessels and distinguish aircraft engaged in
search and rescue operations. ITU-R M.585 governs the MMSI format.

**BACKGROUND**: During WRC-03, MMSIs for other than shipborne equipment
received considerable objections from some administrations. The United
States first presented the issue of MMSIs for aeronautical equipment at
the ITU during the Conference Preparatory Meeting (CPM-2), which were
subsequently discussed and endorsed during a meeting of the
International Maritime Organization (IMO). The main concern expressed by
some administrations was the belief that changing the Radio Regulations
during WRC-03 was premature. Administrations believed that ITU-R studies
are required to ensure that there are no incompatibility issues
regarding the use of MMSIs with the existing GMDSS. Administrations were
also concerned that allowing DSC equipment on aircraft might degrade the
effectiveness of the GMDSS. During WRC-03 several administrations
expressed a need to assign MMSIs to Aids to Navigation as outlined in
Resolution 353 (WRC-03).

**U.S. VIEW:** Recommendation ITU-R M.585 should be reviewed and
modified prior to WRC-07 to take into account the potential exhaustion
of maritime identification digits (MIDs) and MMSIs, and compatibility
with current uses of MMSIs. This review may lead to recommendations for
changes to the Radio Regulations. RR Article **19** should be modified
to allow for assignment of MMSIs to aeronautical stations involved in
maritime SAR. The United States and other administrations are currently
studying, and in some cases implementing, replacement of existing RACON
Transponders with AIS Transponders that require the use of MMSI\'s as an
enhancement to maritime safety. The use of AIS Transponders will permit
detection and identification of aids-to-navigation at greater ranges.
(May 27, 2004)