IFC27/2011 - Submission by Japan Aerospace Exploration Agency (JAXA)

JAXA comments on

“Earth station sitting Guidance”

October 21, 2011

Japan Aerospace Exploration Agency

Introduction

JAXA has been sitting satellite tracking ground stations in Japan and overseas, establishing JAXA Ground Network System. One of them outside Japan is in Perth, Australia. JAXA has been using Perthground station for satellite operation under the ITU regulation space band “2.025-2.120GHz and 2.200-2.300GHz”.

JAXA established the Perth station about 9 years ago and its operation is on going.

Regarding the ACMA’s announcement on the plan to move ENG service from 2.5GHz band to 2GHz band, JAXA is concerned about a possible frequency interference with ground station in Perth.

JAXA has confirmed the ACMA document “Earth station sitting Guidance on the establishment of new Earth stations and other space communications facilities or the expansion of existing facilities (IFC 27/2011)” issued in August 2011.In response to ACMA’s request to comment on the document by October 21, JAXA submits its comments.

We would appreciate to issue“Earth station sitting Guidance” and the opportunity to provide our opinions.

2. Objective

In consideration of orbit trajectory of JAXA satellite in operation, in order to maintain continuous satellite operation in the future, setting up ground station in Western Australia is essential. Therefore, the Perth ground station for space communication is very important for JAXA,

JAXA recognizes that the frequency interference with ENG service is critical issue. In consideration of the coordination with Japanese authorities, JAXA will assess the feasibility of the relocation. JAXA has some comments on “Earth station sitting Guidance” for the assessment.

3. JAXA Comments

JAXA provides the following confirmation items regarding Mingenew area in chapter 4, 5 and 6 of ACMA’s paper if the relocation site would be there.

Currently, JAXA is conducting the feasibility study for future relocation of the Perth station. The first request to ACMA is to ensure the availability of frequency band for space activity specified in ITU regulation. If the frequency band can not be used in the relocation site, JAXA is unable even to investigate the feasibility.

Chapter 4 Section 4.2
No.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?

Comment 1: Request for securingfrequency band

The bands of 2.030-2.049GHz(T), 2.077-2.097GHz(T) and 2.203-2.278GHz(R) are listed in Appendix-A, as frequencies for which longterm operation are secured in the Mingenew area. Frequencies used for JAXA satellite operation are not included in these bands.This means 2.050-2.076GHz, 2.098-2.100GHz and 2.279-2.300GHz bands are unable to use the operation according to Appendix-A. However, in section 4.1.7, it is described that ACMA spectrum Embargo 49 supports the space band “2.025-2.120GHz and 2.200-2.300GHz”. It seems inconsistency to JAXA.

The frequency bands JAXA used for space communication are 2.025-2.120GHz for uplink and 2.200-2.300GHz for downlink as described in section 5.1.1. These bands include all frequencies for JAXA’s existing and future satellites.Therefore, JAXA requests to secure the bands of 2.025-2.120GHz and 2.200-2.300GHz to achieve the long term and stable satellite operation in the Mingenew area.

JAXA will plan to receive data from satellites using X frequency band in the future.However, the useful band width that is described in Appendix-A is narrow, 8.165-8.215GHz. Therefore, JAXA requests that ACMAalso secures Xband to be available with the ITU specified frequency, 8.025-8.500GHz.

JAXA understands that the frequency bands described in Appendix-A are center frequency.

According to Embargo 49, as for the range of 2.100-2.130GHz and 2.280-2.310GHz, new frequency assignments for terrestrial services are restricted within a 300km radius from the center of Yarragadee of Mingenew. JAXA concerns whether the long term and stable satellite operation would be possible, because the time frame is described as “Until further notice” in Embargo 49.

Chapter 6 Section 6.1.1
No.14. The ACMA seeks comment on the usage and effectiveness of the MingenewSatellitePark. Are the current regulatory arrangements effective?

Comment 2: Request for appropriateinfrastructure

Since the Mingenew area is sparsepopulated regions, JAXA concerns the lack of infrastructuressuch as enough electricity and communication facilities. The infrastructure is necessary to operate the ground station.Therefore, JAXA needs the appropriate infrastructure servicesequivalent to PITC and requests the improvement of infrastructure in the area.

Comment 3: Request for achieving the long term and stable operation

JAXA requests for achieving the long term and stable operation of the ground station in the Mingenew area and ensuring that the interference problem with frequency band for wireless service and space communication, due to the population growth like Perth, will never occur in the future.

Chapter 6 Section 6.1.1
No.15. The ACMA seeks comment on the potential to implement a band plan to provide stronger legislative protection to the MingenewSatellitePark.

Comment 4: Request for stronger legislative protection in Mingenew area

JAXA needs the strong legislative protection in MingenewSatelliteParkforachieving the long term and stable operation of the ground station in the area and using the space frequency band under the ITU regulation.