Comments on ACMA IFC 28/2010 by P McGILL BE, MEng, ACMA Accredited Person.

I wish to thank ACMA for providing the opportunity to comment on Satellite matters. The comments provided herein are of a strategic nature and are intended to assist ACMA in its review of Satellite policy.

I have provided BCC copies to other stakeholders to assist in the discussion; if any comment is not clear please call me.

My Comments:

Many of the rules eg Australian interest are discriminatory and would also apply to FS (esp HAPS), and submarine cables etc. I expect that a national interest the same process would also be applied to all foreign space objects beaming in to Aus. Does this apply to NZ space objects wishing to beam into Australia? I suggest this national interest concept be scraped and let the market / entrepreneurs get on with the provision of services- it is their money and provided they comply with licensing rules should be left to get on with their business.

Should let Accredited persons do most of ACMA work. There is now a large cadre of AP’s available to do this type of work and also the national space/terrestrial/space coord. A lot of judgment will /is proposed to be made by ACMA (but we do not know the decision criteria: ACMA should publish a full list of its decision making criteria so that potential customers don’t waste time submitting a proposal only to find it be rejected.), some of this decision making (technical coord etc) can be delegated to your accredited persons as it is fully contestable work!

Should be a RALI, not a separate procedure doc. This will send the message of harmony between Space/ terrestrial - as well as putting all licensing/assignment instructions under a common process ( suggest the extant RALI process). Apparent Bias against satellite re terrestrial (such a HF links, terrestrial systems in Nth Australia etc): these also have similar international coord requirements yet are handled differently by ACMA and have no charges to cater for their ACMA international coord/ ITU notification etc costs- why is this so?).

The draft Procedures tend to be over complex, with all of the simplification of RR in the last decade we would expect more light touch and fewer procedures. Also with Res 49 now adopted, why is there so much comment re paper satellites; I would have thought that ITU due diligence procedures now take care of this issue. Or is ACMA saying these are not working? Will Australian satellite operator be at a competitive disadvantage cf overseas operators?

A decade ago, I though up Deed originally to manage risk of satellite failure (satellite have and do fail in space- should a satellite operating on backup control system be ordered to shutdown?), this issue is still not adequately covered -only through administrative compliance to a deed: but the risk really needs a performance based or technical standards for control node reliability, FMECA, encryption of control codes etc This (Radcom Std?) should be added as a license condition and be supported by ISO9000 QA controlled test/CM systems. (a long time ago, the then Radio Br placed such requirements on remotely located Tx sites such as practically demonstrating failsafe means to turn off a Tx remotely)

Rules limiting trading etc of satellites appears discriminatory and counter to ACMA spectrum objectives, Rad com Act and ACMA active promotion of trading in terrestrial spectrum: I could find no Act that supports such discrimination.