May 19, 2017–The Land Mobile Communications Council says that it is concerned with agenda item 1.3 for the 2019 World Radiocommunication Conference (WRC-19), in which the conference plans to “consider possible upgrading of the secondary allocation to the meteorological-satellite service (space-to-Earth) to primary status and a possible primary allocation to the Earth exploration-satellite service (space-to-Earth) in the frequency band 460-470 MHz, in accordance with Resolution 766 (WRC-15)”.
In an ex parte filing today in IB docket 16-185, LMCC said that “the Resolution 766 proposal has the potential to adversely impact more than 100,000 licensed PLMR operations if not implemented in a way that ensures protection of terrestrial operations from harmful interference.”
“Resolution 766 calls for studies to determine appropriate steps to avoid interference to terrestrial operations,” LMCC noted. It called for “protective measures … as part of any expanded use of the 460-470 MHz band by satellites …”
“Part 90 Private Land Mobile spectrum users should be part of the process for formulating any changes in the rules governing satellite use of the 460-470 MHz band,” it said. “Interested members of the PLMR industry should be part of the testing that is called for by Resolution 766 to confirm that terrestrial radio operations in the 460-470 MHz band can be protected from satellite communications in the band. In this regard, LMCC requests that it have a qualified representative present during the testing, and has made arrangements for such representative to be available for this process. Radios operating in the 460-470 MHz band should not be installed on any satellite until testing determines conclusively that terrestrial operations will be protected from interference.”
The filing continued, “The use of a reduced power density limit, spread spectrum technology and other mitigation measures discussed in Resolution 766 as possible means to prevent interference to terrestrial users should be mandatory for satellites operating in the band. Continuous carrier or other modes of operation that do not monitor before transmitting should be prohibited on satellite radios operating in the band. Satellite operations in the 460-470 MHz band should not be allowed to operate on the Low Power Pool channels designated in 47 CFR § 90.267, because the significantly lower power of such terrestrial operations make them more susceptible to interference.”
The filing also said that “[r]adios designed for satellite use in the 460-470 MHz band should be designed to allow remote reduction of power and/or shut down when the satellite is passing over the United States, in case the interference protection measures implemented as a result of Resolution 766 prove ineffective once the satellite is launched. Until testing proves that terrestrial PLMR operations will be protected, LMCC cannot support co-primary status for satellite operations in the 460-470 MHz band[.]”- Paul Kirby, firstname.lastname@example.org