Posted on Industry Canada website: September 13, 2013
As announced in Canada Gazette notice SMSE-007-13, this consultation seeks comments on a proposed spectrum policy to clarify the use of the frequency band 25.05-25.25 GHz,Footnote 1 which is shared between fixed service (FS) systems and fixed-satellite service (FSS) systems. Respondents who would like Industry Canada to consider other proposals are invited to submit them with supporting rationales.
Under the Department of Industry Act, the Radiocommunication Act and the Radiocommunication Regulations, and given the objectives of the Telecommunications Act, Industry Canada is responsible for spectrum management in Canada. As such, Industry Canada is responsible for developing national policies for spectrum use and effectively managing radio frequency spectrum resources.
One of the objectives of these policies is to ensure that Canadian consumers, businesses and public institutions benefit from the introduction of advanced, affordable wireless communication services in all regions of the country. In pursuing this objective, Industry Canada encourages innovation and investment, with a view to fostering better rates, better services and more choices for Canadians.
The purpose of this document is to consult on whether there is a need to clarify the regulatory relationship between the two primary services in the 25 GHz band in order to facilitate their implementation. This goal is consistent with the policy objective of the Spectrum Policy Framework for Canada of maximizing the economic and social benefits that Canadians derive from the use of the radio frequency spectrum resource.
In 1999, Industry Canada conducted its first spectrum auction for fixed point-to-point and point to multipoint systems in the 24 and 38 GHz bands. At the time, it was thought that this band had significant potential for wireless broadband services. Note that the 24 GHz band includes the bands 24.25-24.45 GHz and 25.05-25.25 GHz.
In March 2008, through the release of Canada Gazette notice DGRB-001- 08,Footnote 2 Industry Canada initiated a consultation on the renewal of licences for the 24 and 38 GHz bands that were licensed through the auction in 1999. It should be noted that not all spectrum was assigned during the 1999 auction and some licences were subsequently returned. In March 2009, Industry Canada published its decisions through Canada Gazette notice DGRB-004-09.Footnote 3 Given the shortage of equipment and a lack of technological development at that time, the Department decided to extend the licence term for auctioned licences in the 24 and 38 GHz bands by five years without applicable fees, and to extend the deadline for system deployment until the end of the extended term. Regarding the unassigned or returned spectrum for the 24, 28 and 38 GHz bands, Industry Canada decided to issue spectrum licences on a first-come, first-served (FCFS) basis and reserved the right to review the FCFS principle should demand exceed supply. All current licences are in Tier 3 service areas.Footnote 4 As these licences will expire in March 2014, this consultation is timely and will provide all licensees with the regulatory certainty required for investment.
The International Telecommunication Union’s (ITU) Radio Regulations allocate the use of the band 24.75-25.05 GHz in ITU Region 2 countries, including Canada, to the fixed-satellite service (FSS) in the Earth-to- space direction. The use of this frequency band for feeder links to the broadcasting-satellite service (BSS) has priority over other FSS uses in this band. In Canada, the feeder links to future BSS space stations that will operate in the band 17.3-17.8 GHz are required to be implemented in the band 24.75-25.25 GHz.
In June 2002Footnote 5 and July 2003,Footnote 6 Industry Canada took its first step toward the use of the 17 GHz BSS band when it issued calls for interest in BSS orbital positions. In July 2006, Industry Canada released an announcementFootnote 7 on the assignment process for Canadian satellite orbital positions, followed by a Call for Applications to License Satellite Orbital Positions,Footnote 8 which was an invitation to submit applications to use the various FSS and BSS frequency bands at a number of orbital positions. This initiative was completed in 2008 and resulted in several approvals in principle for the 17 GHz BSS band for two companies, Telesat and Ciel Satellite LP. Two subsequent licensing processes were initiated in 2009Footnote 9 and 2011.Footnote 10 Based on the outcome of the 2009 call for applications, Telesat and Ciel Satellite each obtained an approval in principle for several orbital positions in the 17 GHz BSS band. Then, following the 2011 call for applications, a new company, 95W Canadian Satellite Communications Inc., obtained an approval in principle for an orbital position in this band. When in operation, these satellites will use the 25 GHz FSS band for their feeder links (uplinks).
Although the deployment of these satellites is not anticipated before 2015, the companies that have obtained approvals in principle are already investing in the design and development of satellites for use in these bands.
This section describes the allocation of the band 25.05-25.25 GHz in Canada, as well as that of other related frequency bands and footnotes, in accordance with the Canadian Table of Frequency Allocations.Footnote 11 In particular, it should be noted that footnote C44 has linked the use of the 17 GHz band by the BSS and the 25 GHz band by the FSS.
Table 1 — Canadian Table of Frequency Allocations GHz
primary serviceBROADCASTING SATELLITEend primary service
primary serviceFIXED–SATELLITEend primary service (Earth-to-space) 5.516
secondary serviceRadiolocationend secondary service
5.515 C43 C44
primary serviceFIXED C45end primary service
primary serviceFIXED-SATELLITEend primary service (space-to-Earth) (Earth-to-space) 5.516 5.517
primary serviceBROADCASTING-SATELLITE C46end primary service
5.515 C43 C44
primary serviceFIXED-SATELLITEend primary service (Earth-to-space) 5.535
primary serviceFIXEDend primary service
primary serviceFIXED–SATELLITEend primary service (Earth-to-space) 5.535
According to the Canadian Table of Frequency Allocations, both the FS and the FSS have a primary allocation in the 25 GHz frequency band.
As demonstrated in Table 2, the allocations for the band 25.05-25.25 GHz in the United StatesFootnote 12 are identical to those in Canada.
Table 2 — U.S. Table of Frequency Allocations GHz
secondary serviceRadiolocationend secondary service US259 G59
primary serviceFIXED-SATELLITEend primary service (Earth-to-space) US271
primary serviceBROADCASTING-SATELLITEend primary service US402 NG163
primary serviceFIXEDend primary service NG144
primary serviceFIXED-SATELLITEend primary service (Earth-to-space) US271
FIXED-SATELLITE (Earth-to-space) NG167
primary serviceFIXEDend primary service
primary serviceFIXED-SATELLITEend primary service (Earth-to-space) NG167
- 17.600-17.700 GHz for stations within a 120 km radius of 38° 49' N latitude and 76° 52' W longitude.
- 17.375-17.475 GHz for stations within a 160 km radius of 39° 42' N latitude and 104° 45' W longitude.
In addition, the coordination process for the band 25.05-25.25 GHz is outlined on the U.S. Federal Communications Commission’s (FCC) website, in the FCC’s Part 25 Rules, Chapter 25.203, “Choice of sites and frequencies,” and Chapter 25.251, “Special requirements for coordination.”Footnote 13 The most relevant paragraphs are set out below:
§ 25.203 Choice of Sites and Frequencies
(l) Applicants for feeder link earth station facilities operating in the 25.05-25.25 GHz band may be licensed only in Economic Areas where no existing FS licensee has been authorized, and shall coordinate their operations with 24 GHz fixed service operations if the power flux density of their transmitted signal at the boundary of the fixed service license area is equal to or greater than -114 dBW/m2 in any 1 MHz.
- When uplink adaptive power control is used, the EIRP used for calculation of the power flux density level should be the maximum possible, taking into account the adaptive power increase.
- The power flux density levels should be calculated based on the actual off-axis gain characteristics of the earth station antenna, and should assume free space propagation conditions.
- When determining whether the power flux density threshold limit is exceeded at the 24 GHz FS licensing boundary, a feeder link earth station applicant must take into account not only the transmissions from its own antenna(s), but also those from any previously authorized feeder link earth stations. Thus, if the cumulative power flux density level at the FS license boundary is in excess of -114 dBW/m2 /MHz, the earth station applicant must either modify its proposed operations such that this value is not exceeded, or enter into coordination with the affected FS licensee.
There is a distinct difference between the Canadian footnote (C44) and the U.S. footnote (NG167) for the band 24.75-25.25 GHz. The Canadian footnote requires that feeder links of BSS space stations operating in the band 17.3-17.8 GHz be implemented in the band 24.75-25.25 GHz, but without limiting the use of the 25 GHz band to FSS feeder links. The U.S. footnote, on the other hand, limits FSS use in the band 24.75-25.25 GHz to feeder links of BSS provided in the band 17.3-17.7 GHz.Footnote 14
The FS and the FSS are both primary services in the band 25.05-25.25 GHz. However, footnote C44 gives priority to the FS over the FSS by specifying that the FSS must not cause interference to FS systems deployed in authorized service areas. As the level of interference is not specified in the footnote, restrictions are indirectly imposed on the FSS, thereby limiting the viability of implementing the FSS in the band.
Industry Canada received comments from Telesat and the Radio Advisory Board of Canada (RABC) on several aspects of footnote C44.Footnote 15 Specifically, Telesat raised concerns regarding the priority of the FSS in the 25 GHz band as compared with the FS. In its comments, the RABC proposed aligning footnote C44 with U.S. footnote NG167 given that there are several subtle differences in the wording of these two footnotes, even though they provide similar descriptions of the uses of the 25 GHz band. Because of these comments, Industry Canada indicated that it would consult on footnote C44 in the future.
The comments provided indicate there is a need to clarify the relationship between the FS and FSS in the 25 GHz band, including changing to the wording of Canadian footnote C44. This will ensure that both primary services can make effective use of the band.
This section presents detailed options and proposals for revisions to Canadian footnote C44. Section 5.1 discusses provisions in footnote C44 related to the linkage between the 17 GHz BSS band and the use of the 25 GHz band by the FSS. Section 5.2 discusses provisions in footnote C44 related to the relative status of the FS and FSS in the 25 GHz band. Finally, Section 5.3 shows the proposed new wording for footnote C44.
The first sentence of footnote C44 creates a link between the 17 GHz and 25 GHz bands. This sentence is currently as follows:
“Feeder links to broadcasting-satellite space stations operating in the band 17.3-17.8 GHz shall be implemented in the band 24.75-25.25 GHz.”
The effect of this first sentence is to require that feeder links to BSS space stations operated in the band 17.3-17.8 GHz be implemented in the band 24.75-25.25 GHz.
The following sections present four options for how the relationship between the 17 GHz and 25 GHz bands could be defined in the future.
5.1.1 Alignment with U.S. Footnote NG167
The first option, as presented in Section 3.4 of this document, would be to align Canadian footnote C44 with U.S. footnote NG167. The effect of the U.S. footnote is to limit the use of the 25 GHz band to FSS feeder links in support of the 17 GHz BSS band.
This option would impose more constraints on the use of the 25 GHz band by FSS than is the case under the current wording of footnote C44.
5.1.2 Alignment with U.S. Footnote NG167 and Addition of Other Types of FSS Applications Associated with BSS
A second option would be to align footnote C44 with U.S. footnote NG167 (as discussed in Section 5.1.1 above), and to broaden the range of permissible FSS uses of the band 24.75-25.25 GHz.Footnote 16 In this case, the band could be used for BSS feeder links, as well as for other FSS applications associated with the BSS.
This option would also impose more constraints on the use of the 25 GHz band by the FSS than is the case under the current wording of footnote C44.
5.1.3 Status Quo
A third option would be to maintain the status quo. This option, as indicated above, requires that feeder links to BSS space stations operated in the band 17.3-17.8 GHz be implemented in the band 24.75-25.25 GHz, but does not limit the type of FSS application that can be operated.
This option would maintain the current constraints on the pairing of the 17 GHz and 25 GHz bands.
5.1.4 Modification of Footnote C44 (First Sentence)
Having analyzed the three options listed above, Industry Canada proposes a fourth option, namely to remove the first sentence of footnote C44. This option would not limit the use of the band 24.75-25.25 GHz to satellites associated with the BSS, and would not require feeder links to BSS space stations operated in the band 17.3-17.8 GHz to be implemented in the band 24.75-25.25 GHz.
This simplification would allow operators to use the frequency band of their choice for the implementation of feeder links to BSS space stations operated in the band 17.3-17.8 GHz.
Although not aligned with the U.S. footnote in terms of text, this option would continue to allow harmonization with the United States in terms of FSS usage of the band 24.75-25.25 GHz. This alignment would allow economies of scale given that satellites could serve both markets, namely the Canadian and U.S. markets.
Footnote C44 does not specify an acceptable level of interference. In fact, the use of the words “will not cause interference” indicates that no interference from the FSS to the FS shall be tolerated, however slight. Industry Canada does not propose to change its policy that it is primarily a fixed band, but some rebalancing is needed to provide certainty to licensees of both services.
A first option for addressing this issue would be to introduce the word “harmful” before the word “interference.” This would clarify footnote C44, as the expression “harmful interference” is defined by the ITU.Footnote 17 Although the status of the FSS would remain lower in priority than the FS, this change would not preclude the establishment of a coordination process, and would clarify an ambiguous situation, thereby providing certainty to licensees of both services.
A second option would be a more comprehensive amendment to footnote C44. This modification would completely eliminate reference to the term “interference,” which would allow for the establishment of a coordination process, and add new text to clarify the status of the FSS.
Both proposed options would provide certainty and protect the continued use of the band by both services. However, for reasons of clarity and directness, Industry Canada proposes adopting the second option.
Based on the proposals in sections 5.1 and 5.2 of this document, the new footnote C44 would be as follows:
5-1 Industry Canada is seeking comments, with supporting justification, on the proposal to amend footnote C44 to clarify the priority of the FS relative to the FSS.
A coordination process is essential when more than one primary service is allocated to a frequency band, as is the case in the band 25.05-25.25 GHz.
There is currently no domestic coordination process for fixed-satellite services in Canada. However, SRSP-324.25, Technical Requirements for Fixed Radio Systems Operating in the Bands 24.25-24.45 GHz and 25.05-25.25 GHz,Footnote 18 contains a section on the domestic coordination of two fixed systems. To summarize, if there is no sharing agreement between operators whose service areas are less than 60 km apart, the need to coordinate will depend on power flux density. An excerpt of the SRSP-324.25 coordination process between two fixed systems is included in Annex A. Coordination between fixed systems in Canada and fixed systems in the United States is governed by the Interim Arrangement Concerning the Sharing between Canada and the United States of America on Broadband Wireless Systems in the Frequency Bands 24.25-24.45 GHz, 25.05-25.25 GHz, and 38.6-40.0 GHz.Footnote 19
As outlined in Section 3.4, the FCC has established a coordination process for earth stations operating in a frequency band that is on equal rights between terrestrial and satellite earth stations. In short, the operator of feeder links to space stations for the band 25.05-25.25 GHz must coordinate with the licensee of the fixed service operating in the same band only if the power flux density of the signal transmitted anywhere within the fixed system’s service area is equal to or greater than −114 dBW/m2 in any 1 MHz band.
Industry Canada is seeking input on the possibility of aligning the coordination process between the FSS and the FS with the coordination process outlined in SRSP-324.25 given that, in both instances, the goal is to protect the FS from harmful interference. All future fixed system licensees would need to take into account existing fixed-satellite Earth stations and accept the effects of their transmissions or try to coordinate with the fixed- satellite licensee to seek an acceptable solution. All future changes to the fixed-satellite Earth stations would need to be recoordinated.
Industry Canada considers that the addition of a coordination process will help to facilitate a balanced coexistence between FS and FSS systems.
Industry Canada will develop the final, detailed technical requirements after the announcement of a decision and in consultation with the RABC.
6-1 Industry Canada is seeking comments, with supporting justification, on its proposal to establish a coordination process between the FSS and the FS. The Department is also seeking comments on whether this process should be aligned with the coordination process outlined in SRSP-324.25 or if another approach should be considered.
August 28, 2013
Engineering, Planning and Standards Branch
This annex is an excerpt from SRSP-324.25, describing the current process for coordinating two fixed systems in the 25 GHz band.
6.2.1 Domestic coordination is required between licensed service areas where the shortest distance between the respective service area boundaries is less than 60 km. The operators are encouraged to arrive at mutually acceptable sharing agreements that would allow for the provision of service of each licensee within its service area to the maximum extent possible.
22.214.171.124 Operators are required to calculate the power flux density (pfd) at the service area boundary of the neighbouring service area(s) for the transmitting facilities. Power flux density is calculated using accepted engineering practices, taking into account such factors as propagation loss, atmospheric loss, antenna directivity toward the service area boundary, and curvature of the Earth. The pfd level at the service area boundary shall be the maximum value for elevation points up to 500 m above local terrain elevation.
126.96.36.199 Deployment of facilities that generate a pfd less than or equal to -114 dBW/m2 in any 1 MHz (pfd A) at the other service area boundaries is not subject to any coordination requirements.
188.8.131.52 Deployment of facilities that generate a pfd greater than pfd A (-114 dBW/m2 in any 1 MHz), but less than or equal to -94 dBW/m2 in any 1 MHz (pfd B) at the other service area boundaries, is subject to successful coordination between the affected licensees in accordance with the following coordination process:
184.108.40.206.1 The operator must notify the respective licensee(s) of their intention to deploy the facility(ies) and submit the information necessary to conduct an interference analysis.
220.127.116.11.2 The recipient of the notification must respond within 30 calendar days to indicate any objection to the deployment. Objection may be based on harmful interference to existing systems only. (*Existing systems include systems that are operational prior to receipt of the notification, or systems that have previously been coordinated.)
18.104.22.168.3 If there is no objection raised, the deployment may proceed.
22.214.171.124.4 If an objection is raised, the respective licensees must work in collaboration to reach a suitable agreement before the deployment of facilities. It is expected that the time frame to develop such an agreement should not exceed 30 calendar days.
126.96.36.199.5 Proposed facilities must be deployed within 120 calendar days of the conclusion of coordination, otherwise coordination must be reinitiated as per section 6.2.2.
188.8.131.52 Deployment of facilities that generate a pfd greater than -94 dBW/m2 in any 1 MHz (pfd B) at the other service area boundaries is subject to successful coordination between the affected licensees.
6.2.3 In any event, licensees are expected to take full advantage of interference mitigation techniques such as antenna discrimination, polarization, frequency offset, shielding, site selection, and/or power control to facilitate the coordination of systems.
6.2.4 All results of analysis on pfd and agreements made between licensees must be retained by the licensees and made available to the Department on request.
6.2.5 If a licence is transferred, the sharing agreement(s) developed between the former licensees shall remain in effect until superseded by a new agreement between the licensees.
6.2.6 In the event a satisfactory agreement or successful coordination between the licensees is not reached, the Department should be informed. In these cases, the Department may impose appropriate technical limitations to facilitate reasonable implementation of systems.
6.2.7 Licensees shall ensure that the pfd at the boundary of unlicensed neighbouring service areas does not exceed pfd B.
6.2.8 While coordination between adjacent block licensees operating in the same vicinity may not be required in most cases, licensees may agree to coordinate certain installations to avoid interference.