1
11 December 10
MID WEST RADIO QUIET ZONE (RQZ)
SUBMISSION BY IRIDUM
Background on Iridium
The Iridium satellite network includes 66 in-orbit LEO satellites, in addition to in-orbit spares. The satellites operate in six orbital planes of eleven vehicles each in nearly circular polar orbits. Our satellites orbit at an altitude of approximately 778 kilometers. The design of our constellation ensures that generally at least one satellite is visible to subscribers from any point on the earth’s surface, covering all of the world’s population.
Iridium utilizes an interlinked mesh architecture to route traffic across our satellite constellation using radio frequency crosslinks between satellites. This unique architecture minimizes the need for ground facilities to support the constellation, which facilitates the global reach of our services and allows us to offer services in countries and regions where we have no physical presence. This allows for increased network security because traffic is routed across our satellite constellation before being brought down to earth via the dedicated, secure gateway, thus reducing the vulnerability to electronic jamming and interception. It is also invaluable in disasters such as the China or Haiti earth quakes where no infrastructure was needed to support the emergency and military workers assisting in the disaster. The network provides handheld voice services as well as data service (10-128 kbps) , including operation from remote unmanned sites.
The constellation is very efficient in its use of the spectrum, reusing the same 9 MHz for user uplinks and downlinks in the 1.6 GHz band. Iridium connects its constellation through re-using many times over 200 MHz at 23 GHz, helping to create a secure system that insures military and civilian disaster operations are successful. Iridium operates gateways and TTACs using 200 MHz in the 19 and 29 GHz bands.
The Iridium head office is in the USA. Iridium holds an Australian Carrier Licence and an Australian Radiocommunication Licence covering the operation of its satellites in providing services throughout Australia and its territories. Re-sellers such as Telstra sell Iridium mobile services to Australian companies and individuals for use within Australia and overseas, both on the ground and in aircraft and ships. Iridium is a significant supplier of mobile services to the Australian Defence Force.
Iridium appreciates the opportunity to participate in the consultation process and to submit its views to the ACMA
Introduction
The Discussion Paper on the proposed Mid West Radio Quiet Zone (RQZ) envisages a new
Frequency Band Plan around the Murchison Radio-Astronomy Observatory Centre (MRO) in WA, latitude 26º 42’ 15” South, longitude 116 º 39’32” East. (see Page 7).
The proposed plan includes coverage of frequencies from 230 MHz to 25.25 GHz within a 100 km radius (200 km diameter and around 31,000 km2 area ). Iridium uses frequencies in this band. The plan also covers frequencies in the band 100 to 230 MHz within a 150 km radius (300 km diameter and around 71,000 km2 area). Iridium does not use this band.
Iridium appreciates the necessity for a RQZ in the interests of radio astronomy and the importance for Australia to host the Square Kilometre Array (SKA). Iridium is keen to assist with the protection of the area but with restrictions minimised through careful targeting rather than blanket prohibitions for this wide band of frequencies all of the time.
Implementation of controls additional to those set out in current ACMA regulatory documents applying to this geographic zone may affect Iridium and other mobile communication users who operate in or transit the RQZ.
Iridium Mobile Terminals
The proposed plan may apply a new prohibition on the operation of Iridium mobile stations operating in the band 1620.1 to 1626.5 MHz in that geographical area of 100 km radius, described in Attachment A of the Discussion Paper. Such a prohibition may unintentionally remove all forms of mobile satellite service, including Iridium and a number of similar satellite systems, over a significant land area.
These mobiles currently operate under Radiocommunications (Communication with Space Object) Class Licence 1998 on frequencies authorised under Clauses 6 (2) and (3). The Discussion Paper proposes on Page 33 that a new clause 8 (5) be added making transmission subject to the requirements that it:
· does not cause harmful interference to radio astronomy services operating in a Radio Quiet Zone; and
· is not inconsistent with the Radiocommunications (Mid-West Radio Quiet Zone) Frequency Band Plan 2010.
Bearing in mind that a user of Iridium mobile user will usually have minimal technical knowledge of the operation of the system, even of the frequency band being used, this potential prohibition raises several questions namely:
· How will the user know that he or she has entered the Mid West Radio Quiet Zone or that harmful interference is a possibility?
· Will the Australian Square Kilometre Array use this narrow band of frequencies used by Iridium?
· If not, is the new requirement necessary in relation to the narrow band of Iridium mobile frequencies?
Safety of Life
Given the remoteness of the location and the fact that many Iridium users in the Outback
carry the phones for safety reasons as well as for normal communication, Iridium suggests that the ACMA consider this potential impact on users. Usage of Iridium mobile stations is infrequent and so the probability of harmful interference in the RQZ is extremely small. The same consideration may apply to services provided by other satellite mobile operators, namely Optus Mobilesat, Inmarsat and Globalstar.
If restrictions on mobile terminals are necessary, Iridium suggests that the protection proposed within the RQZ should take account of the principle that safety of life is of the highest level of importance and takes precedence in any emergency. For that reason Sections 8 (2) and (3) of the (Communication with Space Object) Class Licence 1998 regarding emergencies and consultation should apply in relation to the RQZ.
Action to Inform Users of Mobile Terminals
The following action is therefore proposed so that protection of the SKA is effected in practical terms with minimal disadvantage to the activities of mobile users and their personal safety:
· roads and tracks within the RQZ should be signposted at the 100 km point from the centre of the zone, with reminder signs closer in,
· signs should contain sufficient information to alert the user that:
o the terminal must not be used other than in emergency within the RQZ, or alternatively,
o the user must phone the Observatory to obtain permission to use the phone for non-emergency use.
Given the MRO requires the cooperation of mobile users, it would be to its advantage to take responsibility for provision and updating of the signs on the roads and tracks.
As pilots of aircraft, large and small, increasingly use Iridium, appropriate information should be provided to those pilots through the Defence and Civil Aviation systems as to when Iridium and other satellite mobile terminals cannot be used in the RQZ. Desirably this should be communicated via Airservices Australia aeronautical radio systems on a regular basis regarding specific times rather than via a blanket prohibition.
Other Consultation
A direct consultative mechanism should be set up between the MRO and satellite operators to discuss practical arrangements for protection of the SKA.
Summary
· Iridium is keen to assist with the protection of the area from the time when the SKA becomes operational,
· Iridium questions the need for and practicality of blanket prohibitions in licences, given the potential impact on satellite mobile users - preferably they should be limited to specific frequencies and times in the RQZ,
· Safety of life is a primary consideration in such a remote areas where satellite mobile phones are essential to this safety,
· Mobile class licences should acknowledge this emergency requirement (as they currently do for other specified space research installations),
· Signposting of the area is necessary for information and action by mobile users,
· It would be in the interests of the MRO to provide and maintain the signs,
· A direct consultative mechanism between the MRO and satellite operators may need to be established.