Western Australia Satellite Technology Consortium - ACMA

							WASTAC
Western Australian Satellite Technology and
Applications Consortium

Postal:                  Telephone: + 61 (08) 9387 0343
The Secretary, WASTAC    Fax:        + 61 (08) 9383 7142
PO Box 471
WEMBLEY 6913 WA




            WASTAC Comments on the ACMA Paper:

 Earth station siting – Guidance on the establishment of
  new Earth stations and other space communications
      facilities or the expansion of existing facilities
                               21 October 2011




Contact: WASTAC Secretary
         Richard Stovold
         C/O Landgate, Satellite Remote Sensing Services
         PO Box 471
         Wembley, WA 6913
1. Background Information


The Western Australian Satellite Technology Application Consortium (WASTAC)
operates under a legal agreement with membership comprising the Bureau of
Meteorology, CSIRO, Geoscience Australia, Landgate (Western Australian Land
Information Authority), Curtin University and Murdoch University. WASTAC utilises
Earth Observation resources in the fulfilment of its responsibilities including
supporting the Bureau of Meteorology under the Meteorology Act (1955). WASTAC
and its partners are experiencing an increase in responsibilities and expectations,
particularly for the long-term global monitoring of Earth’s environment, and for
increasingly high-resolution near-term forecasts and severe weather warnings.
WASTAC, through Landgate and the Bureau of Meteorology, provide this
information to the public, private industry, and all levels of government for a wide
range of uses including emergency management (fire and flood), agriculture,
environmental monitoring, infrastructure planning and management, and natural
resource management. WASTAC’s fulfilment of these and other functions
necessitates the availability of real time observations from present and future remote
sensing systems.

Information about the atmosphere, land and ocean is received directly by WASTAC
Earth stations from low-earth orbit (LEO) using communications downlinks in the
1675-1710 MHz (L-band) and 7750-7850 MHz and 8025-8400 MHz (X-band)
Meteorological Services and EESS allocations. The continued availability of direct
reception in these bands is essential for WASTAC’s operations into the future.

The location of WASTAC earth stations for tracking LEO satellites is constrained by
the required north-south and east-west coverage while the satellites are in view
above the horizon (within line-of-sight) of a given receiver. The area of coverage
required, to assist the Bureau’s national and international obligations and Landgate’s
fire and flood monitoring service commitments, extends across the continent and the
surrounding ocean areas. This imposes a requirement for WASTAC earth stations to
be located close to the seaboard in strategic locations.

2. Specific Comments

      3. The ACMA seeks comment on areas of growth in the satellite
      industry. Where is the biggest growth expected? Are there any emerging
      applications for satellite services that are expected to impact spectrum
      requirements?

Continuing advancement of remote sensing payloads on satellite platforms is
leading to larger data sets which require higher data transmission rates. This is
consistent with the growing demand for high spatial resolution and hyperspectral
data to meet government and community needs for severe weather warnings and
high resolution environmental analysis and forecast products. The current trend for
meteorological and environmental satellites is to move to the X-band region of the
microwave spectrum. A number of US and Chinese satellites already provide direct
broadcast at these frequencies. It is anticipated that from 2013 the US polar-orbiting
operational satellite program, which is of vital importance to the WASTAC partners,
will only provide direct broadcast transmissions in X-band1. Therefore, ongoing
access to this part of the spectrum is of great concern to WASTAC. (See response
to Issue 11 below.)

       5. The ACMA seeks stakeholder comment on any additional categories
       of tools that could be used to address the various pressures on
       spectrum used by the satellite and space sectors.

Genuine consideration needs to be given to the value of public good contributed
through WASTAC’s partner’s services to the Australian community and their
economic impacts as well as their contribution to the protection of life and property.
WASTAC partners have a responsibility to provide services for the public good.
These services include using satellite resources to monitor severe weather, and for
ingestion into atmospheric models which in turn contribute to weather forecasting
products that are widely used in routine decision making by industry. The quality of
weather forecasting in severe weather situations and the release of warnings impact
the protection of life and property. Such safety considerations need to be
incorporated in addition to economic, technical and planning measures. The fire and
flood monitoring program undertaken by Landgate also is of high value as a public
good service and ongoing supply of this type of information is critical.


       6. The ACMA seeks comment on using opportunity-cost pricing of
       spectrum for satellite Earth station licensing based on spectrum denial
       caused to terrestrial services.

WASTAC supports the following comments by the Bureau of Meteorology in
their submission to the same ACMA document.

The overarching argument put forward in this discussion paper by the ACMA for
removing earth stations from populated areas is based on the concept of ‘denial of
spectrum’ to anticipated future demand for fixed and mobile wireless broadband
services, and to Electronic News Gathering (ENG) systems. Spectrum denial is then
associated with the economic concept of ‘opportunity cost’ of spectrum which is then
used to support an argument in favour of projected future commercial use of the
spectrum in question. This economic argument focuses solely on the ability to value
the spectrum for commercial purposes and does not take into account or even seek
to mention the economic benefits (past, present and future) arising from the
incumbent users of this spectrum, including the Earth Observations community.

A balanced discussion paper should seek to understand and present the economic
benefits and derived community value of current uses of this spectrum, just as this
paper seeks to present the value (through anticipated demand) of the spectrum as it
would be utilised by the telecommunications industry to provide wireless data and
telephony services. In order to deliver public good services that deliver both direct
economic value and that inform critical decisions regarding safety of life and assets,
Earth observations organisations will continue to rely heavily on direct
communications links with both geostationary and non-geostationary satellites. The
associated utilisation of passive sensing bands must also be considered in light of
the band-specific issues raised in section 4.1 of the discussion paper, and for which
comments are offered in the discussion of Issue 11 below.

Assertions made in the statement “With the ever-growing web of optical fibre
backhaul available, traditional arguments about the need to establish or preserve
satellite and space gateway facilities in populous areas no longer hold.” are not
qualified with timeframes, fibre infrastructure routes (existing or planned), or data
transmission costs. Because “Australia is a vast land mass with an unevenly
distributed population.” fibre links are also likely to be unevenly distributed, and vast
areas will still remain uneconomical to route such links to. The only way they could
become economical would be for users to be charged at a considerable premium, or
for the costs to be subsidised. The provision of redundancy via an alternative high-
bandwidth communications path such as a different fibre link would again increase
costs. Data transmission costs coupled with initial and ongoing infrastructure and
maintenance costs would most likely make the establishment and operation of
remote satellite parks prohibitively expensive for all but commercial organisations
that can pass the costs on to customers. The Bureau and other non-commercial
government, academic and research organisations are not in the position to use this
mechanism to recover costs beyond a certain level. The Bureau’s and similarly
Landgates basic service obligations to the community are recognised as economic
public goods and it is not feasible to fully recover the costs.

       10. The ACMA seeks comment on all matters related to site interference
       protection.

WASTAC supports the following comments by the Bureau of Meteorology in
their submission to the same ACMA document.


While terrain shielding can be used successfully in many satellite reception
configurations involving mainly geostationary orbits, it is a significant hindrance for
tracking LEO satellites. The extent of swaths that satellites can sense during a pass
is related to the length of time a LEO satellite is in the direct line-of-sight of the
receiving station. This time is reduced by obstructions such as trees, hills, buildings,
mountains and other obstacles obscuring the horizon. This means that for LEO
satellites, terrain shielding is not a viable option.

       11. The ACMA seeks comment on issues raised in the band-by-band
       analysis chapter, particularly comments on specific frequency bands.
       Do you agree with the analysis? Why or why not?


WASTAC supports the following comments by the Bureau of Meteorology in
their submission to the same ACMA document.

The 1400-1427 MHz and 2690-2700 MHz bands listed in the discussion paper as
being candidates for active (fixed or mobile) services are dedicated passive sensing
bands as noted in the Radio Regulations Table of Allocations. Any deployment of
active services in these bands is in contravention of the Radio Regulations. Passive
sensing bands are used to measure the “fingerprints of nature” – molecular resonant
frequency ranges that are fixed by nature. Any artificial emissions into these bands
above the thermodynamic noise floor will contaminate the measurements and lead
to loss of information, potentially to the level of effectively blinding satellite sensors
over large parts of the Earth’s surface.

The pressure to meet demand for spectrum by proponents of wireless broadband,
IMT and ENG systems should not lead to a reduction or relaxation in equipment
standards for filtering of transmitters. This is necessary to ensure that their out-of-
band emissions are within internationally agreed limits for adjacent passive EESS
bands. The onus for controlling OOB emissions lies solely with the owners of the
active systems in question and should be a mandatory requirement of the
associated licences.
Section 4.1.2            1400-1427 MHz

This passive band is used for salinity and soil moisture sensing. The ACMA
discussion paper states: “...continued protection against out-of-band emissions from
future fixed or mobile services, except within the RQZ, may not be able to be
supported.” Contamination of this band by emissions from fixed and/or mobile
services is not acceptable and is in contravention of the Radio Regulations Table of
Allocations for all regions. An example of a recently launched (2009) satellite that
uses this band is SMOS2. SMOS was developed as a direct response to the current
lack of global observations of soil moisture and ocean salinity which are needed to
further our knowledge of the water cycle, and to contribute to better weather and
extreme-event forecasting and seasonal-climate forecasting. Measurements made
during the commissioning phase revealed contamination by man-made in-band
emissions over large areas of southern Europe, southern and eastern Asia, the
Middle East and northern Africa (figure 1). Considerable effort and cooperation
between ESA and European spectrum regulators has led to a significant reduction in
interference in this region3.

Due to the ACMA’s diligence, Australia is shown to be effectively free of man-made
interference in this passive sensing band. The Australian remote sensing community
and international users of this data trust that the ACMA will continue to recognise the
importance of keeping it uncontaminated.

Section 4.1.6            1610-1930 MHz

Within this frequency range, the 1675-1710 MHz band is of major importance to the
meteorological and Earth sensing community for LEO and geostationary satellite
downlinks, and for use under the Meteorological Aids (MetAids) classification.
MetAids includes systems such as radiosondes and radiotheodolites. Further
discussions need to reflect this dependency, and this band needs to be given
special attention when considering spectrum allocations that can lead to interference
to ground stations and MetAids systems.

Section 4.1.10           2690-2700 MHz

This passive band is used for salinity and soil moisture sensing. The ACMA
discussion paper states as a foregone conclusion that IMT will be deployed in this
band, as indicated by the sentence: “Operations in this band at Parkes and Narrabri
may need to be reviewed once IMT deployments commence”. Contamination of this
band by emissions from IMT fixed and mobile components is not acceptable and is
in contravention of the Radio Regulations Table of Allocations for all regions.

Section 4.1.13/Section 4.1.14          7250-7850 MHz and 8025-8400 MHz (X-Band)

The X-band is used for direct reception of meteorological data from LEO satellites
owned by other countries, including the US (Aqua, Terra), and China (Feng Yun
series). The expected increase in data volume from non-geostationary MetSat
applications is reflected in Agenda item 1.24 for WRC-12: to consider the existing
allocation to the meteorological-satellite service in the band 7 750-7 850 MHz with a
view to extending this allocation to the band 7 850-7 900 MHz, limited to non-
geostationary meteorological satellites in the space-to-Earth direction, in accordance

2
    http://www.esa.int/esaLP/LPsmos.html
3
    http://www.esa.int/esaLP/SEMB5USOREG_LPsmos_0.html
with Resolution 672 (WRC-07). This 50 MHz extension is necessary to
accommodate satellites planned to be launched in the timeframe 2017–2020.
Access to the above frequency bands from sites with the required line-of-sight
coverage of LEO satellites will therefore remain essential for meteorological and
Earth exploration satellite communications for the foreseeable future.


       14. The ACMA seeks comment on the usage and effectiveness of the
       Mingenew Satellite Park. Are the current regulatory arrangements
       effective?

WASTAC has severe reservations about the cost effectiveness of relocation of
stations to the remote location of Mingenew. Communications costs via optic fibre
would be expensive if they are in place. Maintenance and repairs of a satellite
station and systems would be a costly issue with limited or no on site personnel.


       20. The ACMA seeks comment on any other issues regarding Earth
       station and space communication facility siting that should be
       considered.

As outlined in the background information in section 1 above, WASTAC through the
Bureau has many responsibilities to the Australian public as defined by the
Meteorology Act (1955), as well as to the international meteorology community. The
quality of the WASTAC partner outputs can impact the safety of life and property. In
order to continue to provide a high level of service to the community, the WASTAC
partners relies on an uninterrupted supply of vital data, including data provided by
satellites through direct reception. When considering regulation of Earth Station
siting, the ACMA must give due consideration to the value of provision of services
for the public good as well as the economic and human impact if those services are
hindered.



Matthew Adams

Chairman WASTAC
21 October 2011



WASTAC MEMBERS:
      Bureau of Meteorology, GPO Box 1289, Melbourne, Vic 3001
      Landgate, Leeuwin Centre
       PO Box 471, WEMBLEY, 6913
      Curtin University of Technology,
       GPO Box U1987, PERTH 6845
      CSIRO, Space Sciences and Technology
       GPO Box 664, Canberra ACT 2601
      Murdoch University, South Street, MURDOCH, WA 6150
       Geoscience Australia, PO Box 378 Canberra, ACT 2601