Email:
21October, 2011
The Manager
National Infrastructure, Government and Space Section
Spectrum Infrastructure Branch
Australian Communications and Media Authority
PO Box 78
Belconnen ACT 2616
Subject:The ACMA discussion paper Earth Station Siting
(ACMA Reference: IFC 27/2011 dated 11 August 2011)
Dear Sir/Madam,
SKY Perfect JSAT Corporation (SJC)appreciates the opportunity provided by the Australian Communications and Media Authority (ACMA) to comment on the discussion paper “Earth Station Siting, Guidance on the establishment of new Earth stations and other space communications facilities or the expansion of existing facilities.”
SJC is a commercial operator of communications satellites with its head office located in Tokyo, Japan. With its 15satellites in orbit, SJC is providing a variety of satellite services throughout Asia-Pacific region including Australia, and in such services we are using multiple frequency bands that include 3400 – 4200 MHz (downlink) and 5850 – 6725 MHz (uplink) (“C-band”).
SJC would like to make the following comments to each of the queries on the issues set out in the ACMA discussion paper Earth Station Siting.
1.The ACMA seeks comment on the proposed objectives for the development of a long-term sustainable strategy for the siting of satellite Earth stations and other space communications facilities.
(in Sub-section1.2 Objective)
SJC Comment:
SJCwould like to express its concern onthe proposed objective for the development of a long-term strategy for the siting of satellite Earth stations and other space communications facilities.
SJCbelieves that this Earth stationsiting strategy, if implemented,would cause an adverse impact to the competitive edge of satellite communications, such as ease of the link installation, flexible deployment of the terminal to the target point/area, ease of the international operability, etc., and will also cause an adverse impact to its future growth.
SJC urges ACMA to take into account not only theexisting and/or foreseeable requirements but also the sustainability of competitiveness and growth of satellite communications, and thereforeto reconsider the strategy for the siting of satellite Earth stations.
2.The ACMA seeks stakeholder comment on any additional pressures that should be considered in the context of Earth station siting.
(in Section 2.Pressures on spectrum used by satellite and space services)
SJC Comment:
SJC considers that, among others, C-band continues to be one of the most important frequency bands to the satellite industry and itsusers around the world,and the use of C-band continues to grow. C-band spectrum and the services using this band areessentialand continue to be beneficial tothe future of satellite communications.
SJC is of the view that the ACMA policy making on this matter would havea considerable impacton the use of C-band spectrum, not onlyinside Australia, but also internationally,because C-band is commonly used for international communicationsand therefore such impact on the international use of C-band needs be considered.
3.The ACMA seeks comment on areas of growth in the satellite industry. Where is the biggest growth expected? Are there any emerging applications for satellite services that are expected to impact spectrum requirements?
(in Sub-section 2.1 Satellite industry growth)
SJC Comment:
Because of its natural advantages such as ease of the link installation, flexible deployment of the terminal to the target point/area, ease of the international operability, etc., satellite communications will continue to play an important role in telecommunications and its growth is expected to continue as in the discussion paper. It is stated in the paper that “The growth of the past decade has been observed in a trend towards increased use of higher frequency bands such as Ku-band”, however, SJC is of the view that less growth in C-band compared with Ku- orKa-bandis the sign of insufficient supply of C-band capacity result from recent difficulties to find spectrum and orbital slot available for a new C-band satellite. This means that existing C-band satellite spectrum resource is highly utilized and therefore, the protection of C-band satellite communicationsneeds tobe carefully considered.
Furthermore, SJC would like to point out that the importance of satellite communications, especially in C-band, should not be considered only by its growth and/or cost. As seen in the recent natural disastersin Indonesia, New Zealand and Japan, the significant roles playedby C-band satellite communications in the disaster relief should also be takeninto account.
4.The ACMA seeks comment on the methodology used to establish a benchmark population level below which Earth station operation would be reasonably secure in the long term.
(in Sub-section 2.2.2 Estimating wireless data requirements)
SJC Comment:
At this moment, SJC has no specific comments or alternative to the methodology described in the paper by the ACMA, however SJC considers that the assumed values to calculate such benchmark, i.e. the values in Table 2.1 need to be carefully reviewed and should be examined not in one case but in several possible cases,since difference in the assumption would create difference in the result.
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.
(in Section 3. Tools to facilitate more efficient spectrum utility)
SJC has no comment on this issue.
6.The ACMA seeks comment on using opportunity-cost pricing of spectrum for satellite Earth station licensing based on spectrum denial caused to terrestrial services.
(in Sub-section 3.1 Economic tools)
SJC Comment:
As stated earlierin the comment on the queryNo. 3 above, SJC considers that the importance of satellite communications should not be measured only byopportunity-cost pricing. The values and benefits that would not be brought to the public without satellite communicationsneed to be evaluated fairly and correctly. In this context, aforementionedsignificant role in the disaster relief, where the terrestrial communication systems, including mobile communications, were seriously damagedbythe disasterwould be an element to be taken into account.
7.The ACMA seeks information on any additional planning and technical tools that could be used to manage interference into satellite Earth stations and other space communications facilities.
(in Sub-section 3.2Planning and technical tools)
SJC has no comment on this issue.
8.The ACMA seeks comment on the use of filtering in Earth receive stations and its applicability and usage in interference mitigation.
(in Sub-section 3.2.3 Filters)
SJC Comment:
SJC is of the view thatthe realityof implementing filters to every receiving antennaas interference mitigation is questionable,becausethe performance of actual filters in the market place would not be enough to mitigate interferenceand the implementation of such high performance filters would be more costly and difficult especially for the existing Earth stations.
9.The ACMA seeks comment on alternative methods of interference management should guard bands be reviewed in the future.
(in Sub-section 3.2.4 Guard bands)
SJC has no comment on this issue.
10.
The ACMA seeks comment on all matters related to site interference protection.
(in Sub-section 3.3 Summary of site protection mechanisms)
SJC Comment:
SJCconsiders, as stated above, that the assumptions introducedby the ACMA that form the basis for the analyses should be reviewed and further analyses needto be performed based upon the benchmark population levelsderived from other possible cases.
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?
(in Section 4. Analysis of pressures in spectrum used by space services)
SJC Comment:
SJC would like to comment on the bands 3600 – 4200 MHz and 5925–7075 MHz.
While the number of the Earth stations which are currently licensed is not discussed in this paper, SJC considers it is imperative to make a study on the factual number of Earth stations that need to be dealt with.
SJC would like to further point out that movingthe small Earth Stations (i.e. VSAT earth stations, among others),to “satellite parks” undermines the advantage of satellite communicationssince this type of terminals are commonly deployed at a number ofpoints/areas where they areneeded.
12.The ACMA seeks comment on issues raised in the site-by-site analysis. Do you agree with the analysis? Why or why not?
(in Section 5. Site-by-site analysis)
SJC has no comment on this issue.
13.The ACMA seeks comment on the concept of satellite parks. Do you support this concept? Why or why not?
(in Sub-Section 6.1 Increased use of satellite parks)
SJC Comment:
As stated above, SJC does not support the concept of satellite parks, since this concept may cause an adverse impact to the competitive edge and future growth of satellite communicationsin C-bandas a whole, not onlyin Australia.
14.
The ACMA seeks comment on the usage and effectiveness of the Mingenew Satellite Park. Are the current regulatory arrangements effective?
15.The ACMA seeks comment on the potential to implement a band plan to provide stronger legislative protection to the Mingenew Satellite Park.
(in Sub-section 6.1.1 The Mingenew Satellite Park)
16.The ACMA seeks comment on all issues surrounding the development and establishment of an east coast satellite park, particularly on what factors would be necessary to make it an attractive option for Earth station location.
(in Sub-section 6.1.2 Potential east coast satellite park)
17.The ACMA seeks information on areas that may be potentially suitable for the establishment of an east coast satellite park.
(in Sub-section 6.1.5Summary)
18.The ACMA seeks comment on the concept of defining a maximum guard band width for space services—both on the technical and policy basis for the development of this option and the proposed figures of 10 MHz or one adjacent channel width, whichever is smaller. Comment is also sought on the implementation of geographic exclusion zones and the proposal for a 20 km exclusion zone for C-band Earth receive stations.
(in Sub-Section 6.2 Future options for guard bands)
19.The ACMA also seeks suggestions and information on other incentives that could potentially be offered to encourage the siting of Earth stations in areas of low population density.
(in Sub-section 6.3 Conclusion of potential future strategies for Earth station siting)
SJC has no comment on these issues.
20.The ACMA seeks comment on any other issues regarding Earth station and space communication facility siting that should be considered.
21.The ACMA invites suggestions for alternative approaches to achieving greater opportunities for both terrestrial and space services to achieve their highest value use.
(in Section 7 Summary)
SJC Comment:
SJC has no specific suggestion for alternative on this matter at this moment, however, SJC would like to emphasize again that introduction of the proposed strategy for the siting of satellite Earth stations and the concept of satellite parks will cause an adverse impact on the current and future satellite communications, and thereforeSJC urges ACMA to reconsider the strategy for the siting of satellite Earth stations and the concept of satellite parks.
Finally, SJC would like to thank the ACMA again for the opportunity to comment on this matterand for its ongoingtolerance and transparency in makingspectrum policies.
Sincerely yours,
HiromiKomatsu
General Manager, Spectrum Management Division,
Engineering & Operations Group
SKY Perfect JSAT Corporation
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