XM and Sirius asked the FCC to refrain from allowing ultra-wideband (UWB) vehicular radar systems to operate in the 3.1-10.6 GHz band. The 2 satellite radio companies were among several satellite industry groups replying to issues raised in a petition by Siemens VDO Automotive AG asking the FCC to make changes in the rules adopted for UWB devices. XM and Sirius, authorized to operate in the 2332.5-2345 MHz and the 2320-2332.5 MHz bands, respectively, said UWB vehicular radar systems were likely to cause interference to satellite radios in vehicles due to proximity but because they were “currently restricted to the 22-29 GHz band… the Commission and the satellite radio licensees have assumed that these systems would not present an interference concern.” The addition of UWB vehicular radar systems to the 3.1-10.6 GHz band would make the former assumption invalid, particularly as there was no technical analysis of potential interference, they said: “While vehicle manufacturers will likely engineer radar systems to avoid interference to satellite radio operating within the same vehicle, this does not address a situation in which a radar system in one car is directly pointed at a trunk- or roof-mounted satellite radio antenna in an adjacent vehicle.” XM and Sirius asked the Commission to either require additional technical analysis to address the issues or, if the rule were changed, to allow the parties ample time to object to equipment certification applications. The Satellite Industry Assn. (SIA) also asked the Commission not to allow vehicular radars in the band, saying they were likely to increase the potential for harmful interference to fixed satellite service (FSS) earth station receivers in the band. It said nothing “in the record shows a need for additional spectrum for UWB vehicular radars, while the SIA has made substantial showings of the risk of harmful interference from such devices in the 3.1-10.6 GHz band.” Northrop Grumman and Raytheon submitted joint comments telling the FCC it shouldn’t approve the radars “near or in the 23.6-24.0 GHz band without adopting strict limits to reduce the potential for increased interference that likely will result under standards being proposed by manufacturers.” Both companies are contractors for the National Polar- Orbiting Operational Environmental Satellite System (NPOESS) that, when operational, will use that band to provide “space- based, remotely sensed environmental data,” they said: “While the parties recognize the potential benefits from vehicular radars,… protection against harmful interference to remote passive sensors deployed by NPOESS is important… because the capabilities of [NPOESS] to offer significant safety-of-life benefits, support for homeland security and defense objectives.” Meanwhile, Siemens VDO said opposition to its proposal by the National Academy of Sciences’ (NAS) Committee on Radio Frequencies (CORF) were based on a concern that its radars were more likely to cause harmful interference to earth exploration satellite service (EESS) sensors in the 23.6-24 GHz band, which it said was untrue: “CORF fails to acknowledge that any threat of future interference to EESS will be reduced due to existing rules that, starting in 2010, require all UWB vehicular radar devices to sharply attenuate emissions appearing 30 degrees or more above the horizontal plane.” Siemens said its device wouldn’t increase the interference potential any more than pure pulsed devices.
The FCC shouldn’t adopt new receiver interference immunity performance specifications for fixed satellite service (FSS) dishes at the risk of affecting the market negatively, PanAmSat said: “Attempting to impose receiver standards in a dynamic environment or in bands shared by users with different characteristics can undermine market incentives, stifle innovation and raise costs for consumers.” PanAmSat said existing receiver requirements the FCC had adopted for adjacent satellite interference at 2 degrees spacing determined receiver specifications, creating an incentive for manufacturers to protect their own devices. However, additional requirements will increase manufacturing and equipment costs and possibly stifle innovation, PanAmSat said. If the Commission must create new parameters, the company said, directionality of receivers should be taken into account. The Satellite Industry Assn. (SIA) agreed with PanAmSat saying in its own comments that new requirements could “freeze” the development of satellite technology: “Satellite operators should be free to implement new technologies and improve the quality of their service. Otherwise, they may lose the ability to provide services that are competitive with terrestrial offerings and available throughout the U.S. at prices that are distance insensitive.” Meanwhile, Mobile Satellite Ventures (MSV) told the Commission that it should consider adopting standards, particularly in the L-band (1-2 GHz), based on concerns raised in the ancillary terrestrial component (ATC) proceeding. The company said Inmarsat’s opposition to the implementation of ATC was based on the fact that its mobile terminals were particularly sensitive to interference: “Because the Commission has not established performance standards for L-band mobile terminals, Inmarsat can claim any overload threshold for its terminals in order to needlessly restrict the power and location of its competitors’ base stations.” MSV proposed 2 solutions: (1) Adoption of a minimum overload threshold for L-band mobile terminals by using a “best practices” overload threshold. The mobile terminal least susceptible to interference would be used as the “best practices” terminal and no interference protection could be sought when exceeding the overload threshold. (2) Claims of certain overload thresholds must be proved with testing data: “By floating such exaggerated claims of overload susceptibility before the Commission without any technical support, opponents of spectrum flexibility place the Commission and other proponents of spectrum flexibility in the difficult position of having to disprove these claims.”
The FCC amended its space station licensing rules with minor modifications in satellite fleets and earth stations. In response to a Satellite Industry Assn. (SIA) request that modifications be approved after a 10-day review, the Commission said 10 days wasn’t enough time to complete a review, but streamlined modifications could be completed if space station operators notified the it 30 days before relocation. Operators would have to certify that operations would continue under existing coordination agreements and that service wouldn’t lapse for customers, the FCC said. It proposed similar parameters for minor modifications of earth stations, but only where the station antenna would continue pointing at the old satellite in a new location. If an operator chose to change the direction of the antenna to point at a new satellite, the Commission would consider the modification to be major and would require new authorization, it said. Non-U.S. satellites on the permitted space station list would be required to follow the same procedures, the Commission said.
Cingular Wireless and the Satellite Industry Assn. (SIA) asked the FCC, in separate petitions, to reconsider its decision to allow unlicensed operation of ultra-wideband (UWB) devices under Part 15 of the Commission’s rules. Cingular argued that the decision violated Sec. 301 of the Communications Act, which bars wireless transmissions without a license and “unquestionably requires a license for all low- power transmissions.” As a result, Cingular said, the Commission can’t authorize UWB operations on an unlicensed basis. It told the agency that Congress had identified 4 services in which spectrum use could be permitted without a license and that UWB didn’t fall into any of them. “The Commission’s authority to permit unlicensed UWB operations is therefore nonexistent,” Cingular said: “Once these devices proliferate, there will be no way to cure the interference they cause. This was a problem Sec. 301 was intended to prevent.” Cingular and other wireless companies have contended that the FCC erred in allowing UWB devices to operate under Part 15, in part because there hasn’t been extensive enough testing of the impact on commercial mobile radio service (CMRS) operations and Enhanced 911. Some commenters said the FCC should have conducted tests using actual UWB devices before granting authorization. Cingular said in its May 22 petition that the FCC’s UWB decisions were arbitrary and capricious: “The Commission recognized that any changes to Part 15 must continue to insulate FCC licensees from harmful interference and that, given the importance of this noninterference condition, it ’should be cautious until it has gained further experience with this technology.’ Yet the Commission rejected every conservative measure proposed by the CMRS industry to protect their operations from harmful interference and to ensure that UWB devices do not interfere with E911 calls.” It said the FCC moved forward without “an adequate test record,” even though its Technical Advisory Committee had suggested testing would be critical in any UWB decision. In a separate petition and engineering analysis, SIA said the FCC should revamp its UWB rules because they exposed fixed satellite service (FSS) operations in 4 GHz downlink bands to harmful interference. Rollout of “ubiquitous” UWB devices will interfere with C- band downlinks, creating concern for satellite operators because FSS systems make wide use of that band, SIA said. Those frequencies are used for program distribution to cable headends and radio/TV broadcast stations, broadband communications to Navy vessels, commercial weather data distribution to airlines and position location for truck fleets. “UWB interference could jeopardize the billions of dollars that FSS operators, customers and distributors have invested in FSS systems for commercial and national security purposes and could interrupt vital FSS services,” said SIA, which is seeking reconsideration of an earlier FCC rejection of a previous challenge by the group. SIA said the earlier denial was based on criticisms of the association’s findings “that do not withstand scrutiny,” the petition said. SIA argued that the interference-to-noise ratio adopted by the Commission, unlike that used by SIA, would expose FSS earth station receivers to harmful interference.
Midway Games announced winners of its Midway Sports MLB SlugFest Nationwide Cheerleader Tryouts. Chicago publisher said winners Sia Darmos and Amanda Gilbert would appear in upcoming Midway Sports videogames and each would receive $5,000, as well as “opportunity to travel and participate in exclusive Midway Sports promotional events.” Midway Vp-Mktg. Helene Sheeler said “fans rallied around this unique promotion” since it kicked off Jan. 14. In March 21-April 11 span, gamers cast their votes online to select next 2 Midway Sports cheerleaders, company said.
The FCC shouldn’t include the 3650-3700 MHz band in its decision on additional spectrum for unlicensed devices, the Satellite Industry Assn. (SIA) said in reply comments. SIA said it earlier had provided documentation that it said showed interference from unlicensed devices to existing co- frequency incumbent fixed-satellite service (FSS) operations, none of which were disputed by later comments. SIA said the “impossibility of a global allocation, the difficulty in assessing interference from future fixed service networks” and “the further challenge of protecting co- and adjacent- frequency” FSS operations seemed to elicit skepticism rather than enthusiasm for that allocation. Adopting rules for the band would be difficult because operators of future unlicensed devices wouldn’t have models of expected services, undermining “any incentives to develop standards and design products for the band,” SIA said. “Within the next few months, the FCC will auction new Fixed Service licenses in the band, making the extended C-band even more intensely used than today. Let that be enough,” it said. “The FCC should not simultaneously propose adding unlicensed products into the 3650-3700 MHz band.”
FCC Office of Engineering & Technology Chief Edmond Thomas said Tues. the Commission expected to start a proceeding by year’s end to open a debate on “interference temperature,” which he called “an extremely difficult technical concept to implement.” He told a National Spectrum Managers Assn. conference in Arlington, Va., that the FCC also planned to open a proceeding by year-end on cognitive radio technologies. On both counts, the end-of-year period is “exactly what we are shooting for and it looks like we are going to do that.”
Independent MultiFamily Communications Council doesn’t require emergency relief from or reconsideration of an FCC ruling removing it from its satellite frequency (IB 98-172), the Satellite Industry Assn. (SIA) said in a report to the FCC. The ruling was made after the Commission concluded that the 18.3-18.58 GHz band should be designated for the fixed satellite service (FSS), thus requiring terrestrial users to vacate the band over the next 10 years and prohibiting any new applications for terrestrial use in the band. The SIA said it found no basis in the IMCC’s bid for reconsideration and emergency relief. Relief or reconsideration from an order requires that the petitioner suffer irreplaceable harm if not granted, which the IMCC itself actually admitted wasn’t the case, SIA said. The IMCC also waited 6 months before filing its relief request, which SIA said was much too long after the May 8, 2003, date on which the rule changes became effective to be taken seriously. The IMCC also doesn’t satisfy any aspect of the 4-point standard for granting emergency relief as established in the Va. Petroleum Jobbers case, nor will it further the public interest, the SIA said.
Service rules the FCC adopts for the operation of dedicated short-range communications (DSRC) stations in the 5.85-5.925 GHz band (5.9 GHz band) should consider the co- primary uplink operations of fixed satellite service (FSS) earth stations in both the 5.9 GHz band and the adjacent band from 5925-6425 MHz, the SIA said. “Widespread deployment of DSRC stations could limit where new FSS earth stations can be located” because of the potential for harmful interference, the association said. To protect both operations, it said rules should be adopted to protect existing FSS operations and require prior coordination of new DSRC and FSS earth stations. Beyond that, a “coordination zone” could be established, SIA said, “outside of which no coordination would be necessary.”
Developers of wireless local area networks (LANs), including Wi-Fi systems, urged the FCC to follow through on a recent notice of inquiry and make additional spectrum available for unlicensed devices, including TV broadcast bands. But several commenters, including some local govts. and private wireless groups, cautioned that technology to avoid interference to incumbents wasn’t far enough along to warrant the FCC’s taking the “risk” of opening that spectrum now. Broadcasters raised particular concerns about the potential impact on the DTV transition.