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Final Push

WRC Advisory Committee Members at Odds on Proposal for Lunar Communications

The U.S. stance on communications with space operations planned for the moon sparked some disagreement at a World Radiocommunication Conference Advisory Committee meeting Monday. WAC held a 90-minute virtual meeting, long by the group’s standards, as planning intensifies headed into WRC-23, slated to start at the Dubai World Trade Centre in the United Arab Emirates on Nov. 20, 2023.

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Lockheed Martin wants the WRC to approve a future item on lunar and cislunar communications, explained Scott Kotler, the company’s director-technical regulatory engineering. Cislunar is the area between the moon and earth. Lockheed has been active in space, and has a proposal for a lunar landing module.

Kotler cited an August filing the company made at the FCC in docket 16-185. “The need urgently exists to accommodate the planned communications and data transmission requirements of long-term and continuous commercial and scientific operations on and around the moon,” the filing said: “Administrations in all three ITU Regions have announced and are pursuing lunar missions, with remote unmanned exploration already underway, and with human visits to the Moon set to occur as early as 2025. Lockheed said “permanent bases and regular space travel (both crewed and remote-controlled) will be established by the end of this decade or in the early 2030s. This is not speculation.”

CTIA continues to have concerns with this proposal” and doesn’t believe “it has been fully developed to address the concerns by WAC members,” said Michael Mullinix, CTIA assistant vice president-regulatory affairs. “The proposal is quite encompassing, exploring the spectrum use for five separate architectures to support lunar communications and could necessitate the need for at least five separate agenda items,” he said.

At this time there’s been no basis for the specific candidate bands ... nor the amount of spectrum needed to support this aspirational use,” Mullinix said: “The necessary regulatory studies are just beginning in the ITU.” WAC members from AT&T, Verizon, and Qualcomm supported CTIA. WAC agreed to forward the proposal to the FCC as a non-consensus paper.

It is a very interesting issue of great public import,” said Tricia Paoletta, WAC chair. Paoletta and other members suggested the FCC seek additional comment.

3 GHz Spectrum

Another area of continuing disagreement is agenda item 1.2, which looks at the future of the 3.3-3.4 and 3.6-3.8 GHz bands. Mobile operators want to see the band allocated for international mobile telecommunications (IMT) on a regional basis. WAC’s proposal offers three different views. Major carriers and equipment makers say the spectrum should be allocated for wireless broadband, aligning it with the 3rd Generation Partnership Project standardized band class for 5G.

On the other extreme, Lockheed Martin supports a position that WRC should make no changes. ITU sharing studies “show that IMT and radiolocation coexistence is not possible in the same or nearby geographical areas requiring very large separation distances and as such IMT deployments in one country would impact radiolocation in other countries” and “the U.S., domestically, has not made a determination as to whether or how a mobile use would operate within the 3300-3400 MHz band,” the company would find.

Lockheed doesn’t stand alone in its concerns but is the “only radar manufacturer that is a WAC member,” Kotler said. The WAC approved all three positions to be forwarded to the FCC.

International Bureau Chief Tom Sullivan said the FCC is counting on the WAC to work out differences before the conference. “We are almost one year from the start of the WRC in Dubai” and the conference preparatory meeting “is just around the corner,” he said. “You have all been hard at work, as evidenced by the fact that the WAC has already produced a significant number proposals for the WRC-23 agenda at this meeting and that’s going to pave the way for successful U.S. leadership both regionally at CITEL [Inter-American Telecommunication Commission] and internationally at ITU," he said.

Sullivan asked the WAC to find consensus where possible. “I strongly encourage and challenge you to look for common ground,” he said: The U.S. “stands a much better chance of success internationally when we present a clear, consistent, and united message abroad. … As the issues and discussions get more complex, we depend on you, the WAC members for guidance and support.”

NTIA International Spectrum Policy Division Chief Charles Glass warned WAC to expect a “large set of proposals” from his agency before May and a key prep meeting for WRC. “I am confident the views and recommendations presented by the WAC today will form the basis for U.S. proposals at the upcoming CITEL meeting in November,” he said. The FCC reconstituted the WAC in March for two years, after its last charter expired.The group last met in February.