WASTAC
Western Australian Satellite Technology and Applications Consortium
Postal:Telephone: + 61 (08) 9387 0343
The Secretary, WASTACFax: + 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. WASTACutilises 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-band[1]. 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. Thefire 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 associatedlicences.
Section 4.1.21400-1427 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 SMOS[2]. 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 region[3].
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 4.1.102690-2700 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 4.1.147250-7850 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 850MHz with a view to extending this allocation to the band 7 850-7 900MHz, limited to non-geostationary meteorological satellites in the space-to-Earth direction, in accordance with Resolution672(WRC07). 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
- CurtinUniversity 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
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