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The Manager 2 June, 2015

Space and National Interest Planning Section

Spectrum Infrastructure Branch

Australian Communication and Media Authority

PO Box 78

Belconnen ACT 2616

(by email: )

Submission to the ACMA consultation on Proposal to remake Radiocommunications (Communication with Space Object) Class Licence 1998

Firstly, Omnispace Australia is pleased for the opportunity to make a submission to the ACMA consultation on this subject, however considering the discussions we have had with the ACMA on the use of the MSS S-band in Australia it is disappointing that the ACMA had not raised this issue with Omnispace prior to going public with these preliminary views. Omnispace recognizes the need to undertake an action to establish a future framework that extends beyond that which expires later this year, however, this “sun setting” of the prior framework was known for some time.

As the ACMA is aware Omnispace Australia is a stakeholder in the use of the internationally allocated MSS S-band, has established an operational satellite Earth station at Ningi (Qld.), is licenced for feeder link operation with the OMNISPACE F2 MSS S-band satellite network, and has had discussions with the ACMA about obtaining an S-band licence at Ningi for TT&C operation with the USASAT-30F satellite network.

Consequently, our main interest in this consultation concerns the ACMA proposal to remove the mobile-satellite service frequency ranges 1980–2010 MHz and 2170–2200 MHz from the space object class licence (ie Q2).

Omnispace strongly opposes this for the reasons detailed in Annex 1, and supports the retention of these frequency segments in the proposed new 2015 Class licence.

Omnispace Australia agrees with the ACMA that the existing Class Licence has been operating effectively and efficiently, and that its ongoing effect should be preserved.

The Omnispace Australia response to each of the remaining questions in the ACMA consultation paper is detailed in Annex 2.

Please contact me if you need any clarification or additional information, and I would be pleased to assist the ACMA in evolving a mutually satisfactory result.

Sincerely,

[ signed ]

Les Davey ph: 0418 312 134

Managing Director

Omnispace-Australia


Annex 1: Omnispace Australia response to consultation paper Q2.

Q2. Is the proposal to remove the mobile-satellite service frequency ranges 1980–2010 MHz and 2170–2200 MHz from the space object class licence supported? If so, or if not, why?

Omnispace Australia strongly opposes the proposal to remove the internationally allocated MSS S-band segments from the Space Object Class Licence provisions.

The detailed reasons are set out below:

1. The existing Class Licence has been operating effectively and efficiently, and its ongoing effect and frequency segments should be preserved

2. The segments proposed to be deleted are internationally allocated for MSS S-band, and assigned for co-primary MSS operation in Australia and should be preserved

3. There is significant internationally interest in the use of this band for MSS services as evidenced by the number of ITU-R S-band filings:

Number of filings (GSO + NGSO)

1980 - 2010 MHz 2170 - 2200 MHz

Notified 18 46

Coordination stage 320 334

4. The ACMA Embargo 23 established in 1996 has prevented the licencing of MSS S-band operation in Australia, so it is misleading to state in the consultation that there are no licences issued in the S-band segments, and the “…lack of satellite use of the band in Australia…”

5. The ACMA filed the SIRION MSS S-band satellite network, opposed the recent suppression of this network, and recently advanced the SIRION-1 MSS S-band filing to the CR/C stage, presumably to support the introduction of MSS S-band services in Australia

6. The filing of the former ICO-P satellite network was subsequently replaced by the OMNISPACE F2 satellite network which has been in service since 2013, and there are a number of other international MSS S-band filings which may want to provide services to Australia

7. The outcomes of WRC-15 are yet to be determined, and it would appear that changes to this S-Band allocation are not expected. Anticipating that no change would be made to this ITU allocation would make it inappropriate at this time to make decisions on how the MSS S-band should be assigned in Australia

8. Omnispace Australia has the ACMA Earth station licences for feeder link operation at Ningi to OMNISPACE F2

9. Omnispace Australia is keen to establish an MSS S-band service for low-cost ubiquitous terminals in rural and remote Australia for M2M and other services that would benefit from the ability to Class Licence these terminals

10. The exclusive assignment of S-band for TVOB in Australia was understood to be an interim arrangement near major cities, and should not effect the provision of MSS S-band services in rural and remote Australia


Annex 2: Omnispace Australia response to other consultation paper questions.

The Omnispace Australia response to each of the other questions in the ACMA consultation paper is detailed below.

Q1. Is the proposal to excise the radionavigation-satellite service into a new class licence supported? If so, or if not, why?

Omnispace Australia has no view on the Radionavigation – Satellite Service Class Licence issue.

Q3. Are the changes proposed by the ACMA with respect to the operation of mobile ship stations by qualified operators and in accordance with relevant Resolutions of the IMO supported? If so, or if not, why?

Omnispace Australia has no view on this question.

Q4. Considering the proposed space object class licence as a whole, are there any issues the ACMA has not considered in its development of the class licence that need to be addressed? If so, please provide further detail of the issue.

Omnispace Australia has listed a number of issues that the ACMA should consider in its response to Q2.

Q5. Is the ACMA’s proposed approach to coexistence in the 1240–1300 MHz band between radionavigation-satellite service and the apparatus licensed use under the AUS101 and AUS1A footnotes appropriate? If so, or if not, why?

Omnispace Australia has no view on this question.

Q6. Can operators of the 5010–5030 MHz band please provide further detail on the characteristics, purpose and expected service introduction of operations in this band?

Omnispace Australia has no view on this question.

Q7. Are there other frequency ranges that should be considered for inclusion in the class licence? If so, further detail on the characteristics, purpose and expected service introduction should be provided.

Omnispace Australia is not aware of other frequency ranges that should be considered for inclusion in the class licence, at this time.

OMNISPACE Letter to ACMA