0 Slide 0 Preventing Interference from Earth Station Vessels National Spectrum Managers Association May 19, 2004 Mitchell Lazarus | |

1 Slide 1 Introduction  ESVs seek to operate in several bands shared with the Fixed Service (FS):  MHz  MHz  GHz  GHz  The FS is concerned only about MHz.  Even there, the FS does not oppose ESVs if FS operation is protected.

2 Slide 2 FS is Entitled to Protection from ESVs  Long-standing FCC policy: Incoming services must protect incumbents.  The FS is entitled to full interference protection from ESVs at MHz.  ESV pleadings object to the FCC’s “overt bias toward the FS” and ESVs’ quest for “fair and balanced rules”  These statements misunderstand the FCC’s statutory obligation.  As the interfering latecomer, ESVs are subordinate to the FS.  Past ESV authorizations have included this condition.

3 Slide 3 Fixed Service Use of C-Band  FS applications include:  public safety communications  coordinating railroad trains  controlling natural gas and oil pipelines  regulating the electric grid  backhauling wireless telephone traffic  These links are constructed for % % availability.

4 Slide 4 Threat from ESVs  Transmit beams on ESVs threaten interference into coastal FS receivers.  The threat is exacerbated by:  in-motion sources  lack of terrain  possible transmission from non-coordinated regions.

5 Slide 5 ESVs Claim “No Past Interference”  ESV assertions of “no demonstrated interference” must be disregarded.  Signals from an ESV are intermittent, transient, and hard to track down.  Identifying an ESV as the source of interference requires taking the FS link out of service for an extended period.  ESV providers have refused to give FS operators the information needed to link particular ESVs to particular interference events.

6 Slide 6 Frequency Coordination Is Necessary But Not Sufficient  Frequency coordination of ESVs is fundamentally different from that for fixed earth stations.  Frequency coordination depends a precise knowledge of each facility’s location.  A moving source opens the risk of transmission from a non- coordinated location.

7 Slide 7 Needed Protective Measures (1)  Bar ESV operation on C-Band within 300 km of the U.S. coastline.  OR...

8 Slide 8 Needed Protective Measures (2) 1.Require frequency coordination; ESVs must suspend transmission on route segments where coordination failed. 2.Renew frequency coordination every six months. 3.Require a GPS device to shut down the ESV in non- coordinated waters. 4.Give FS operators real-time access to ESV data and a 24/7 contact capable of shutting down ESV transmissions. 5.Limit ESV coordination as to bandwidth, satellites, azimuths, and elevations. 6.Limit ESV license terms to two years. 7.Limit ESVs to ships of 5,000 gross tons or larger.

9 Slide 9 Who Bears the Costs?  The FS acknowledges these measures will entail costs for ESVs and may limit service.  The costs and limitations result from the ESV industry decision to use congested C-band frequencies.  If ESVs do not protect the FS, the FS will incur costs and/or lose revenue. ... which amounts to forced subsidy of ESVs by the FS.

10 Slide 10 Conclusion  The FCC should adopt the interference-prevention measures set out by the FS.

11 Slide 11 Thank you! Mitchell Lazarus | |