Trade Law Daily is a Warren News publication.
Ligado: Ample Evidence Otherwise

Weather Interests Warn More of Terrestrial 1675-1680 MHz Use Woes

Weather and disaster monitoring interests voiced more worries about terrestrial wireless use of the 1675-1680 MHz band, in filings late last week in FCC docket 19-116. Friday was the deadline for comment on proposed allocation and service rules for the band (see 1905210011). Weather interests oppose Ligado's terrestrial low-power service plans for the band and its alternatives for delivering NOAA weather satellite data (see 1704130023).

Sign up for a free preview to unlock the rest of this article

Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.

The Satellite Telemetry Interagency Working Group -- which includes NOAA, the Army Corps of Engineers, U.S. Geological Survey and the National Park Service -- said there needs to be a "thorough and unbiased analysis" of the 5 MHz band before there can be any recommendation of safeguards to protect incumbent geostationary orbiting environmental satellites (GOES) data collection system ground stations. It said if such an analysis finds commercial in-band emissions are spectrally incompatible, incumbent receivers should retain primary status, senior rights, and all associated protections. Without protection zones for nonfederal users of GOES satellite data, legions of weather organizations "will face significant adjacent band interference" from wireless operations in the band that could make downlink functionality useless, the American Weather and Climate Industry Association said.

The FCC should wait for the results of a NOAA study on sharing and possible mitigation, and in the interim, set up a process for weather, water and climate interests to register their 1675-1695 MHz receive-only antennas, said the American Geophysical Union, American Meteorological Society and National Weather Association. In that registration, they asked the FCC request information about filers' timeliness requirements for the weather data and whether alternative methods of accessing the same data are available. If there's a rulemaking on the band, voluntarily registered users should deserved interference protection on par with incumbent federal users, they said.

Ligado, in comments to be posted, said it has provided ample evidence in recent years that commercial use of the band won't disrupt any existing federal entities, while unregistered entities in the band will be able to obtain the same information. It said NOAA moving its radiosonde operations out of the band and into the 401-406 MHz band, which is to be done by 2021, definitely won't be affected by shared commercial use of the band. The company backs the proposed protection zones around NOAA operations. Ligado said an FCC order should be clear that entities that aren't registered and not designated recipients of NOAA satellite data aren't entitled to protection. The satellite firm urged a nationwide license area instead of one based on partial economic areas, and that the band be available for uplinks, downlinks and time division duplex instead of just downlinks, pointing to the adjacent 1670-1675 MHz band as having that flexibility.

If the 1675-1680 MHz band is to be shared, it should be used for uplink services, since the lower power of user equipment, along with adequate protection zones for incumbents, is the most sensible route for making that work, the National Spectrum Management Association said. It said the FCC followed similar logic restricting the 1695-1710 MHz band for uplink use only since it was adjacent to meteorological earth stations in 1675-1695 MHz. It urged geographic licensing of the band because nationwide licensing would eliminate some bid options and likely some bidders.