Avoiding damage to C-Band users – WRC-19 Agenda item 10: Satellite Industry Views

October 23, 2019 11:54 am Published by

Members of the GSC have been highly involved alongside administrations and other spectrum stakeholders in spectrum management at ITU-R and regional levels to allow co-existence and future development of radio-communication services. The GSC relies on administrations to continue supporting the development of all telecommunications sectors in a balanced manner by providing them with the regulatory certainty required for continued operations and future sustainable investment.

WRC-19 was tasked by Resolution 238 to study the potential identification of up to 33.25 GHz for IMT-2020 under WRC-19 Agenda Item 1.13. With the IMT-2020 technology still in development and demand for nascent 5G services uncertain, the plentiful existing spectrum already available for IMT should be used before additional spectrum is identified for IMT. With IMT-2020 deployment in these bands targeting mainly densely populated areas with traffic hotpots and with wireless devices increasingly operating in license exempt spectrum, it is unclear how much additional spectrum will be required, if any, beyond that currently identified or to be identified through WRC-19 agenda item 1.13. Furthermore, as demonstrated by a study performed by LS Telcom, a significant amount of spectrum harmonized for IMT in the bands below 3 GHz has not yet been licensed or used by IMT[1].

Despite the uncertainties regarding IMT-2020 technologies and 5G demand, and the significant amount of unlicensed or unused spectrum already identified for IMT, the mobile community is proposing that studies be conducted to identify even more spectrum for IMT at WRC-23.   There is no consensus among regions on whether additional spectrum is needed for IMT at all, much less what bands are most appropriate.  The current proposals have a wide varying of proposals in the bands from 3 to 24 GHz; including critical bands for the satellite industry as well as the other industries.

The GSC is strongly opposed to such studies. The C-band, Ku-band and Ka-band are core frequency bands for the satellite industry, and are heavily used today. Introducing IMT-2020 into these bands would interfere with existing satellite services, negatively impact existing investments and harm competition by limiting the ability of satellite operators to meet the growing demands of satellite users, including broadcasters, government, enterprises and end users, wherever located.  In particular, introducing IMT-2020 into these bands which today are used to provide satellite-enabled connectivity to those not served or underserved by IMT-2020 would widen – not narrow – the digital divide.

It is critical the satellite bands in the C-band, Ku-band and Ka-band remain preserved, as they are all in extensive use based on multi-billion dollar investments from satellite operators and users worldwide. Due to the satellite life cycle (>15 years), long term regulatory certainty and reliable access to spectrum is required for future planning to support new use cases – many of which will be essential for the satellite contribution to the 5G network of networks.2 The GSC believes that at the international level the key is to find the right balance, which provides adequate spectrum for a variety of industries and technologies to allow each to develop and offer services to the public, unimpaired by each other, and without detrimental impact to crucial existing services. Today, satellite networks provide connectivity to users no matter where they are located, in metropolitan and rural areas alike, and whether they are at work, at home, on an aircraft or a ship or a vehicle. No other technology offers this reach or these capabilities to the entire world.

Therefore, the GSC recommends administrations to continue supporting the development of all industries by providing both IMT-2020 and satellite interests with the spectrum access and regulatory certainty required for continued operations and future sustainable investment, which is vital to all telecom sectors. Considering the amount of spectrum currently identified for IMT-2020, the potential candidate bands under WRC-19 Agenda item 1.13, and the anti-competitive and adverse operational impact of the proposed additional IMT-2020 identification, no new agenda item for additional IMT-2020 identification should be favored by administrations.

 

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[1] https://www.lstelcom.com/fileadmin/content/marketing/news/2019_Study_LicensingUseofMobileSpectrum.pdf

[2] https://www.ecodocdb.dk/download/e1f5f839-ba17/ECCRep280.pdf

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This post was written by Global Satellite Coalition