Operation of Unmanned Aircraft Systems Under the Fixed Satellite Service Allocation

1

AERONAUTICAL COMMUNICATIONS PANEL (ACP)

TWENTY SEVENTH MEETING OF WORKING GROUP F

Montreal, Canada 17 – 26September 2012

Operation of Unmanned Aircraft Systems Under The Fixed Satellite Service Allocation

(Presented by John Mettrop)

1.INTRODUCTION

1.1Aviation has traditionally operated its systems in spectrum that has been allocated to an aeronautical safety service such as aeronautical moile (R), aeronautical mobile satellite (R), aeronautical radionavigation or aeronautical radionavigation-satellite. This policy is recognised in the current Handbook on Radio Frequency Spectrum requirements for Civil Aviation

1.2By using such spectrum allocations aviation has gained the following advantages:-

• Guaranteed access to spectrum
• Control over the frequency bands in which it operates
• Clear identification of frequency bands where aeronautical systems operate
• Radio regulatory protection in accordance with the relevant provisions of the Radio Regulations including articles 4.10 and 15 (specifically 15.8 & 15.28).
• The application of a safety margin and the use of reasonable worst case scenarios during compatibility study.
• Planning undertaken in accordance with planning rules that have been accepted by ICAO as safe.
• Assignments that have been successfully co-ordinated,such that there are no outstanding caveats, with all requisite authorities prior to operational use
• That all assignments have been appropriately registered with ICAO and where appropriate the ITU and hence will be taken into account in the co-ordination of other assignments
• The application of a consistent policy across all systems and frequency bands
• The advantages listed above have proven to provide the requiste protection and certainty required by aviation for the operation of safety services.

2.discussion

2.1With the increasing use of remotely piloted aircraft systems (RPAS) and the desire to operate such systems in a mixed environment with aircraft that rely on a pilot being on-board the aircraft ICAO recognised the safety implications and formed a working group to address the various issues. It was quickly recognised that the command and non-payload communications (CNPC) would need to be standardised in order to ensure the safety of airspace and hence require SARPs[1]action.

2.2Given that the CNPC links have been acknowledged as affecting safety they need the appropriate regulatory and technical protection and hence should operate under a service designation that recognises and is recognised by the ITU as being a safety service. In this case that would either be the aeronautical mobile (R) or aeronautical mobile satellite (R) services.

2.3Proposals have however been made that systems operating under a Fixed Satellite Service (FSS which is not a recognised safety service) allocation could provide capacity to address the beyond line of sight satellite element of the CNPC spectral requirement. These proposals are being made by operators who have everything to gain and nothing to lose as opposed to aviation who could lose a significant amount if precedents are set that when applied to other aeronautical spectrum would have an adversely impact on the protection of the systems operating in those frequency bands.

2.4The ICAO policy to the last conference where a similar proposal was made was to support the need to ensure that allocations used, in particular, for RPAS command and control, ATC relay and sense and avoid in non-segregated airspace are in the AM(R)S, AMS(R)S and/or ARNS and do not adversely affect existing aeronautical systems. This policy was further clarified in the preceding text to indicate that if a parent radio service were used then a footnote would be required and that that footnote would have to clearly identify the band being used to provide the aeronautical safety service as well as the appropriate level of priority and pre-emption.

2.5Nothing has so far changed that warrants a change in the ICAO policy from the last conference. The FSS is not even a parent radio service for the AM(R)S, AMS(R)S or the ARNS and therefore should not figure in the consideration of spectrum for RPAS unless they are willing to change the Radio Regulations in such a way as to provide access to the AMS(R)S with the relevant level of priority and pre-emption and regulatory protection afforded to AMS(R)S.

2.6If this is not achieved then effectively aviation is agreeing that it can operate its safety services under a non-safety allocation which probably has not completed successful co-ordination and hence could be regarded as operating on a secondary basis. The consequence is that aviation does not require specific spectrum for its system and can operate under a more generic allocation.

2.7If an approach can be shown to the satisfaction of aviation to provide the necessary technical and regulatory protection, guarantee access to spectrum through a means other than a commercial contract and would be applicable to all aeronautical systems then it may be possible to agree to the use of systems operating in the FSS for the provision of CNPC. However this approach would have to be proven before ICAO changes its policy on the spectrum suitable for the provision of CNPC.

3.Recommended action by the meeting

3.1The meeting is invited to:-

• To agree to the proposed changes to the ICAO position detailed in the attachment to this document

Attachment

WRC-15 Agenda Item 1.5

Agenda Item Title:

To consider the use of frequency bands allocated to the fixed-satellite service not subject to Appendices30, 30A and30B for the control and non-payload communications of unmanned aircraft systems (UAS) in non-segregated airspaces, in accordance with Resolution 153[COM 6/13] (WRC12);

Discussion:

[Flimsy01]

At WRC-12 whilst no new satellite allocations were made to support remotely piloted unmanned aircraft system (UASPRAS[2]) control and non-payload communications (CNPC), the aeronautical mobile satellite (R) service (AMS(R)S) allocation made through footnote 5.367 was upgraded to a table allocation. Additionally the co-ordination requirements in the frequency band 5030-5091 MHz were amended. Studies have been made in the band 5030-5091 MHz between AMS(R)S and the ARNS and separately with the new AM(R)S allocation made to the terrestrial UAS component. However there is currently

It has to be noted that no AMS(R)S satellite system currently operatinges in the 5030-5091 MHz frequency band that couldto support current/near-term UAS CNPC.

Whilst AMS(R)S is the appropriate type of service allocation under which to support the satellite component for UASRPAS command and control and ATC relay in non-segregated airspace. However, WRC-15 AI 1.5 asks for studies for the use of FSS allocations for UASRPAS applications.

Existing systems operating in the fixed satellite service (FSS) systems in the frequency bands 12/14 GHz and 20/30 GHz bands may have the capability of offering access to spectrum for UAS CNPC. However the fixed satellite service is not recognised in the ITU as a safety service and a majority of these systems d which have been brought into use under article 11.41 indicating that there were unfavourable findings which had not been resolvedunder the conditions that the principles detailed below can be fulfilled.

Technical Standards and Recommended Practices (“SARPs”) for CNPC will be developed in ICAO. UAS FSS links would have to be designed to comply with those SARPs. While studies by the ITU-R appear tohave been carried out show that from a technical standpoint the FSS in the 12/14 GHz and 20/30 GHz frequency bands to assess their may have the capability toof supporting UAS CNPC, regulatory measures will be required in order to address the additional regulatory protection required by aeronautical systems as well as the mobile nature of RPASUAS . In addition regulatory measures will be required to address some of the principles detailed below.

AMS(R)S is the appropriate type of service allocation to support the satellite component for UAS command and control and ATC relay in non-segregated airspace. However, WRC-15 AI 1.5 asks for studies for the use of FSS allocations for UAS applications.

In this connection, Article 15 of the RR states that special consideration shall be given to avoiding interference on distress and safety frequencies. Further, recognizing that transmissions on distress and safety frequencies and frequencies used for the safety and regularity of flight require absolute international protection and that the elimination of harmful interference to such transmissions is imperative, administrations undertake to act immediately when their attention is drawn to any such harmful interference. (ref. RR n°.15.8 and RR n°. 15.28)

In order to fulfil the requirements above the use of FSS allocations for UAS will have to fulfil the following principles:

1)Identification of frequency bands where aeronautical safety systems are operating

2)Guaranteed access to the band with priority and pre-emption where necessary

2)3) That the assignments and use of the relevant frequency bands have to be consistent with article 4.10 of the Radio Regulations

4)A safety margin can be applied during sharing studies.

5)That the principles behind any agreement could be applied to other aeronautical services without any adverse impact ensuring a consistent policy across all systems and frequency bands.

3)6)That a realistic worst case conditions can be applied during sharing studies

In order to fulfil the requirements above the use of both AMS(R)S and FSS allocations for UAS will have to fulfil the following principles:

1)Knowledge that any assignment operating in those frequency bands has been planned in accordance with known planning rules that have been accepted by ICAO as safe.

2)Knowledge that any assignment operating in those frequency bands has been co-ordinated with all of the requisite authorities and been approved by those authorities and that any caveats placed on approval of that assignment have been addressed and resolved.

3)That all assignments are registered appropriately whether that be in the master international frequency register or the relevant regional or global ICAO database and therefore taken into account in co-ordination of other assignments.

4)That all of those assignments operate in accordance with the radio regulations and the definitions contained therein and they can claim protection from other systems.

5)That interference to systems is reported in a transparent manner and addressed in the appropriate timescale.

6)A realistic worst case conditions can be applied during sharing studies.

7)A consistent policy across all systems and frequency bands

ICAO Position:

To oppose the use of systems operating in the Fixed Satellite Service for the provision of remotely piloted aircraft system command and non-payload communication links until all of the above principles have been addressed to the satisfaction of ICAOTBD

[1] SARPs are defined as follows:-

• Standard - Any specification for physical characteristics, configuration, material, performance, personnel or procedure, the uniform application of which is recognized as necessary for the safety or regularity of international air navigation, and to which Contracting States will conform in accordance with the Convention. In the event that a State finds it impracticable to comply in all respects with any such international standard but allows a less stringent practice, immediate notification to ICAO is compulsory under Article 38 of the Convention. In case a more stringent regulation is adopted, notification to ICAO is compulsory only when such regulation is applied also on foreign licence holders and aircraft. However, in a Resolution of 5 February 1999, the ICAO Council made it clear that, in principle, national requirements “more exacting” than the SARPs would be detrimental to the framework of the Chicago system within which international civil aviation has developed and continues to develop. In this Resolution the Council also called upon each Contracting State to utilize the multilateral mechanism of ICAO where it believes that changes to the content or level of implementation of the Standards and Recommended Practices in the Annexes to the Chicago Convention are necessary or desirable;

• Recommended practices - Any specification for physical characteristics, configuration, material, performance, personnel or procedure, the uniform application of which is recognized as desirable in the interest of safety, regularity or efficiency of international air navigation, and to which Contracting States will endeavour to conform in accordance with the Convention.

[2] The term remotely piloted aircraft systems has now been adopted in ICAO as the term to be used when referring to unmanned aircraft systems.