IFC27/2011 - Submission by European Space Agency

Comments of the European Space Agency

to the ACMA document

SF27-2011 (Earth station siting)

1 Contents:

1-Introduction and background 2-Future satellite requirements 3-Tools for efficient spectrum usage 4-Band-by band analysis 5-Western Australia analysis 6-Future strategies for Earth station siting 7-Conclusions

2 1 Introduction and background

The European Space Agency (ESA) wishes to thank the Australian Communication and Media Authority (ACMA) for being offered the opportunity of commenting on the ACMA document on Earth station siting (IFC27-2011)

Since the early years after its creation, the European Space Agency (ESA) has enjoyed scientific and technical cooperation with the Australian government. The most important element of this cooperation has been the operation of Earth stations on the Australian territory. In addition to the Gnangara/Landsdale station near Perth, a second station has been implemented in New Norcia with a large 35-m antenna; such station operates there since 2003. The choice of the New Norcia site was agreed with the Australian government to avoid the criticalities of the Gnangara/Landsdale station related to coordination with the terrestrial services. The construction of the New Norcia Earth station has represented for ESA a sizable long- term investment (56 Million AUD).

A few years ago ESA was informed by the Australian authorities that the assignment of licences for the Gnangara/Landsdale station was becoming unmanageable, due to new national frequency arrangements as well as to the increasing urbanization around the site (and the associated coordination problems). Eventually ESA agreed to terminate all activities in that station by end-2015. ACMA indicated that in exchange they “…would undertake to seek to establish a long term arrangement for future protection and access to spectrum at New Norcia, possibly along the lines of the radio quiet zone established for the SKA in West Australia”. Unfortunately the later evolution of the national frequency plan (and in particular the relocation of ENG systems in the 2 GHz band) meant that the protection of the New Norcia station couldn’t be achieved as originally envisaged at the time of the agreement for the Gnangara/Landsdale station closure. After many studies and negotiations, it was agreed to limit the use of the 2025-2110 MHz and 2200-2290 MHz bands to a 10 and a 15 MHz sub-band needed for continuing the operations of an existing ESA satellite. Use and protection of other segments of the 2 GHz bands for tracking satellite/launchers during LEOP (Launch and Early Operations Phase) and will have to be negotiated between ESA and ENG on a case by case basis. For the other bands covered by the Implementing Arrangement between ESA and Australia, ESA was offered the possibility to purchase apparatus licences for the area around New Norcia.

It is to be noted that the use of the ESA Earth stations in Australia is regulated by a Treaty and an associated Implementing Arrangement (IA) document between the Australian Government and ESA. In particular, for the frequency management aspects, a specific Article in the IA and the associated Annex 1 defines the rights and responsibilities of the 2 parties and details which frequency bands can be used by ESA in accordance with international and national regulations. For these frequencies the Australian Government “…will use its best endeavours for the implementation of radiofrequency interference protection measures… (Article 10)”.

3 An updated Treaty and a new version of the IA will be signed 04-Oct-11, the latter covers three main new elements: 1- the termination of the Gnangara/Landsdale station operations in the bands 2025- 2110 MHz and 2200-2300 MHz bands; 2- the authorization for ESA for obtaining the apparatus licences for the entire frequency ranges 7145-7235 MHz, 8400-8500 MHz, 22.55-23.15 GHz, 25.5-27.0 GHz, 31.8-32.3 GHz and 34.2-34.7 GHz at New Norcia; 3- the limitations on the use of the 2 GHz bands at New Norcia.

All the elements above need to be taken into consideration to better understand the ESA background and the reasons for some of the ESA comments that will be provided in this document.

4 2 Future satellite requirements

Point 2: The ACMA seeks stakeholder comment on any additional pressure that should be considered in the context of Earth station siting

In addition to the elements of pressure mentioned in the context of Earth station siting (pressure from increased bandwidth requirements by terrestrial users and by the satellite industry) ESA would like to indicate other elements that play a role in the increase of satellite requirements in terms of traffic or geographical constraints or frequency choice limitations:

1- Increased requirements for cross-support to other satellites of other space agencies 2- Interference risks associated to the geographical co-location of stations supporting satellites of various operators (scientific and commercial) 3- Necessity to select frequencies that can be supported by all the Earth stations operating a given satellite mission. In other words, any “blockage “of a given frequency at a given Earth station due to local national constraints translates into a blockage of that frequency for all the other Earth stations associated to that mission.

Point 4: The ACMA seeks comments on the methodology used to establish a benchmark population below which Earth stations operation would be reasonably secure in the long term.

ESA has no comments on the methodology used, but would like to stress that the ESA Earth station in New Norcia may deny parts of the spectrum only for an area that is largely below the 25000 inhabitants threshold. The new ENG bands may be the only exception to this; specific measures have been studied for this band. The fact that all other bands may deny spectrum to a scarcely populated area is confirmed by the agreement in the new Implementing Arrangement that ESA will be able to buy apparatus licences for these bands. It is to be noted that the indication in the Appendix A table that the 7-GHz and 8-GHz bands are not secure in the long term at New Norcia is in contradiction with what said in this chapter of SF27-2011: “…Earth stations operation would be reasonably secure in the long term” ESA is extremely concerned about what indicated in Appendix A for New Norcia and seeks reassurance by ACMA that, with the exception of the 2-GHz bands, the other bands are secure for long-term usage in New Norcia.

5 3 Tools for efficient spectrum usage

Point 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.

ESA would like to confirm that the technical/operational tools mentioned in this chapter of SF27-2011 are indeed already applied to the existing ESA New Norcia station. The New Norcia station presents good filtering and antenna discrimination capabilities, it is built in a scarcely populated area (well below the 25000-inhabitants threshold) and respects exclusion cones to further improve its isolation. Clearly this doesn’t protect the station from interference by terrestrial systems with unwanted emission levels much higher than the satellite signal received.

ESA would like also to stress that an additional tool for facilitating sharing is the suitable planning by terrestrial services on the use of channels in sparsely populated areas. For example, if only a subset of the total amount of channels available to ENG is necessary near New Norcia, it should be possible to agree to have the ENG using only channels not in overlap with frequencies used by the Earth station. Devices like ENG have large tuning ranges and are not expected to require all the channels available in parallel in the New Norcia vicinity.

6 4 Band-by-band analysis

Remark: The list of space services at the beginning of Chapter 4 in SF27-2011 doesn’t include EESS.

Point 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?

1400-1427 MHz: ACMA is invited to note that the protection against out-of-band emissions from adjacent bands is regulated by WRC Resolution 750 (WRC-07). Consequently the protection of this band for EESS (passive) measurements is supposed to be assured also on the long term.

2025-2120 MHz: It is to be noted that even a transfer of the New Norcia facilities to Mingenew wouldn’t be sufficient for the protection of this band, since the Embargo 49 doesn’t include the necessary guard band 2015-2025 MHz.

2200-2290 MHz: It is to be noted that even a transfer of the New Norcia facilities to Mingenew wouldn’t be sufficient for the protection of this band, since the Embargo 49 doesn’t include any necessary guard bands like 2190-2200 MHz. Furthermore, it looks like the transfer of 2 GHz functionalities from Gnangara/Landsdale to New Norcia (scarcely populated area) is not sufficient to ensure space operations in this band. Even the expected low density of ENG systems around New Norcia is creating problems.

7145-7235 MHz: This frequency range is not mentioned in this list of satellite bands and is partially missing also in Embargo 49 (7145-7200 GHz), while it represents a key band already largely used by the ESA station in New Norcia. This band is covered by the Implementing Arrangement between the Australian Government and ESA and was proposed for apparatus licences. Additionally, the Embargo 49 doesn’t include the necessary guard band 7235-7245 MHz. Therefore, even a transfer of the New Norcia facilities to Mingenew wouldn’t be sufficient for the protection of this band.

8025-8400 MHz: This band is discussed only for its use by FSS uplinks and not for its use for EESS downlinks. The EESS usage is included the Implementing Arrangement between the Australian Government and ESA.

8400-8500 MHz: This frequency range is not mentioned in this list of satellite bands, while it represents a key band already largely used by the ESA station in New Norcia. This band is covered by the Implementing Arrangement between the Australian Government and ESA and was proposed for apparatus licences.

7 It is also to be noted here that even a transfer of the New Norcia facilities to Mingenew wouldn’t be sufficient for the protection of this band, since the Embargo 49 doesn’t include the necessary guard band 8500-8510 MHz.

Other bands: A certain number of bands (25.5-27 GHz, 31.8-32.3 GHz, 37-38 GHz and 40-40.5 GHz) are not mentioned here, although they are included in the Implementing Arrangement between the Australian Government and ESA and some of these bands were proposed for apparatus licences.

8 5 Western Australia analysis

Point 12: The ACMA seeks comment on issues raised in the site-by-site analysis. Do you agree with the analysis? Why or why not?

ESA would like to provide comments only for the New Norcia station, since an agreement on the closure of the 2-GHz activities at Gnangara/Landsdale has been reached.

The New Norcia analysis in the document is limited to the 2 GHz operations. An agreement on the limitations to the use of 2-GHz bands at New Norcia is included in the new version of the Implementing Arrangement between the Australian Government and ESA. For the part related to sharing with ENG, the results of the on-going 2.5 GHz auction will tell if some frequency ranges will be available for space operations in addition to the ranges identified in the Implementing Arrangement.

ESA is concerned by the fact that no other band is mentioned in the new Norcia section 5.1.3. ESA would appreciate if the other bands included in the Implementing Arrangement are included and discussed in this section. ESA would appreciate seeing text indicating that:  these bands are covered by the Treaty and Implementing Arrangement between the Australian Government and ESA;  that ESA can obtain apparatus licences for some of these bands;  that the use of these bands at New Norcia is considered secure in the long term.

The last point would consequentially require that the bands 7.135-7.235 GHz and 8.400- 8.500 GHz are removed from the column “may influence medium-term availability” in the New Norcia entry in Appendix A Earth stations table.

9 6 Future strategies for Earth station siting

Point 13: The ACMA seeks comment on the concept of satellite parks. Do you support this concept? Why or why not?

While the concept of satellite parks presents clear advantages for an operator that is starting his activity in Australia and has no specific geographical constraints, the advantages of this concept are more limited for an operator that already has a deployed infrastructure on the ground:  the large financial costs associated with the relocation,  plus the technical/operational risk of having a period of forced inactivity during the switch-over,  plus the risk of losing skilled personnel that refuses to be relocated, are all serious issues that limit the attractiveness/viability of such a relocation.

Furthermore it is to be stressed that, even neglecting any economical aspects, the satellite parks present limitations that can be seen in the Embargo 49 case for Mingenew. More specifically:

1 Embargo 49, while blocking any new terrestrial user in a given area, still allows existing terrestrial users to continue operating. This implies that coordination with these users will still be needed until they continue operating. 2 Embargo 49 doesn’t cover the necessary guard bands, as already mentioned in section 4 above. Some of the bands used by ESA are not covered. This implies that no full protection of these bands is ensured anyhow.

10 7 Conclusions

ESA appreciates the ACMA initiative to create Space Parks in Australia for siting Earth stations and has provided comments to this.

Nevertheless the level of investments made by ESA for the implementation of the New Norcia Earth station doesn’t make the relocation of services out of New Norcia a financially feasible option.

Furthermore the Embargo 49 wouldn’t anyhow give ESA a decisively better sharing environment than at New Norcia, given:  the absence in Embargo 49 of some bands covered by the Implementing Arrangement for New Norcia,  the absence of guard bands to fully protect an hypothetical ESA station in the Mingenew park and  the necessity to coordinate with existing terrestrial users.

ESA therefore still plans to maintain the New Norcia Earth station for the foreseeable future and counts on the relevant agreements between the Australian Government and ESA (Treaty and Implementing Arrangement) to ensure the protection of the frequencies for that station in the form indicated in those documents. ESA has already agreed to simplify the issue by purchasing apparatus licences for the bands of interest at New Norcia, as allowed by the Implementing arrangement; this should ensure proper protection of those bands (with the exception of the 2 GHz case).

In this respect ESA is rather concerned by the fact that SF27-2011:

 doesn’t consider a number of bands mentioned in the Implementing Arrangement and  shows the 8 GHz bands (crucial for the future operations of ESA satellites) as not suitable for long-term operations at New Norcia, in contradiction with the Implementing Arrangement.

ESA would therefore kindly ask ACMA to modify these points in the document.

ESA remains at ACMA disposal for any clarifications on the comments provided.