Board on Physics and Astronomy

Comments in the Matter of Amendment of Parts 2 and 35 of the Commission’s Rules to Allocate Spectrum and Adopt Service Rules and Procedures to Govern the Use of Vehicle-Mounted Earth Stations in Certain Frequency Bands Allocated to the Fixed Satellite Service (IB Docket No. 07-101). The National Academy of Sciences, through the National Research Council's Committee on Radio Frequencies (CORF), hereby submits its comments in response to the Commission's May 15, 2007, Notice of Proposed Rulemaking in the above-captioned docket (NPRM). In these comments, CORF discusses the importance to the Radio Astronomy Service (RAS) of observations at 14.47-14.50 GHz and supports portions of the Commission’s proposal, as modified below, to protect RAS observations in this band with coordination requirements. (August 16, 2007)
Comments in the Matter of Amendment of Part 90 of the Commission’s Rules (WT Docket No. 07-100). The National Academy of Sciences, through the National Research Council's Committee on Radio Frequencies (CORF), hereby submits its comments in response to the Commission's May 14, 2007, Notice of Proposed Rulemaking in the above-captioned docket (NPRM). In these comments, CORF notes its concern about the potential impact of proposed permanent fixed microwave operations in the 4940-4990 MHz (4.9 GHz) band on radio astronomy observations. Accordingly, if the Commission decides to authorize such permanent fixed operations, it should enact rules requiring prior frequency coordination of such operations, in order to protect radio astronomy observations. (August 13, 2007)
Comments in the Matter of Recommendations Approved by the Advisory Committee for the 2007 World Radiocommunication Conference (IB Docket No. 04-286). The National Academy of Sciences, through the National Research Council's Committee on Radio Frequencies (CORF, see attachment), hereby submits its comments in response to the Federal Communication Commission's January 9, 2007, Public Notice in the above-captioned docket (DA 07-26). In these comments, CORF discusses the importance of the scientific observations performed only in the Earth Exploration Satellite Service (EESS) bands at 36.0-37.0 GHz and the need to protect such observations. CORF also urges the Commission to reinstate a mandatory power limit in Document WAC/151 in order to protect that EESS band. (February 5, 2007)
Comments in the Matter of Recommendations Approved by the Advisory Committee for the 2007 World Radiocommunication Conference (IB Docket No. 04-286). The National Academy of Sciences, through the National Research Council's Committee on Radio Frequencies (CORF), hereby submits its comments in response to the Federal Communications Commission's November 1, 2006, Public Notice in the above-captioned docket (DA 06-2262, hereinafter “Notice”). In these comments, CORF discusses the importance of the scientific observations performed only in the Earth Exploration Satellite Service (EESS) bands at issue in the Notice and the need to protect such observations. CORF also expresses general support for the use of mandatory out-of-band emission limits on active services to protect the adjacent and nearby EESS bands at issue herein. (December 6, 2006)
Comments on a Notice of Proposed Rule Making by the Federal Communications Commission (FCC) in the Matter of Service Rules and Procedures to Govern the Use of Aeronautical Mobile Satellite Service Earth Stations in Frequency Bands Allocated to the Fixed Satellite Service (IB Docket No. 05-20) The National Academy of Sciences, through the National Research Council's Committee on Radio Frequencies1 (CORF), hereby submits its comments in response to the Commission's February 9, 2005, Notice of Proposed Rulemaking in the above-captioned docket (NPRM). In these comments, CORF discusses the importance to the Radio Astronomy Service (RAS) of observations at 14.47-14.50 GHz and supports the Commission’s proposals to protect RAS observations in this band with coordination requirements and with a revised footnote in the Table of Allocations. (June 30, 2005)
Comments on a Notice of Proposed Rule Making by the Federal Communications Commission (FCC) in the Matter of Amendment of the Commission’s Rules to Facilitate the Use of Cellular Telephones and Other Wireless Devices Aboard Airborne Aircraft (WT Docket No. 04-435). In these Comments, CORF supported proposals in the NPRM that could have the effect of reducing the likelihood and severity of interference from airborne cellular telephone transmissions to sensitive radio astronomy observations. (May 26, 2005)
Comments on a Notice of Proposed Rule Making by the Federal Communications Commission (FCC) in the Matter of Unlicensed Operation in the TV Broadcast Bands and Additional Spectrum for Unlicensed Devices Below 900 MHz and in the 3 GHz Band (ET Docket Nos. 04-186 and 02-380, see April 7, 2003). In these Comments, CORF supported the FCC’s proposal to prohibit transmissions by unlicensed devices on TV Channel 37 (608-614 MHz). The harm to radio astronomy observations by such transmissions would be significant, protection of radio astronomy sites would likely be difficult or impracticable, and there is no evidence that transmissions on Channel 37 are necessary to achieve the Commission’s goal of promoting unlicensed services. CORF also suggested other means of preventing harmful out-of-band interference to radio astronomy observations, primarily limiting transmissions by unlicensed devices on TV Channels 36 and 38. (September 1, 2004)
Comments in an Inquiry Regarding Carrier Current Systems including Broadband over Power Line Systems (ET Docket No. 03-104, see also July 7, 2003), in response to the Commission's February 23, 2004, Notice of Proposed Rulemaking. CORF supported the Commission’s proposals for protecting existing users of the spectrum from potential interference from broadband-over-powerline (BPL) transmissions. (May 3, 2004)
Comments on Facilitating Opportunities for Flexible, Efficient, and Reliable Spectrum Use Employing Cognitive Radio Technologies (ET Docket No. 03-108), in response to the Commission's December 30, 2003, Notice of Proposed Rulemaking. CORF demonstrated that those aspects of the basic concepts underlying cognitive radios that are intended to protect against interference to other users appear to ignore or are incapable of protecting passive users of the spectrum for scientific observation in bands allocated for such uses. Accordingly, CORF strongly urged the Commission to maintain the current Section 15.205 prohibition against intentional unlicensed transmissions in certain restricted bands. In addition, CORF recommends adoption of certain other measures to protect passive scientific observation of the spectrum, and the critically important data being gathered by such observers. (May 3, 2004)
Comments on the Notice of Inquiry and Notice of Proposed Rule Making by the Federal Communications Commission (FCC) in the Matter of Establishment of an Interference Temperature Metric to Quantify and Manage Interference and to Expand Available Unlicensed Operation in Certain Fixed, Mobile and Satellite Frequency Bands (ET Docket No. 03-237). The FCC asked for comments on a new "Interference Temperature" model for quantifying and managing interference. CORF supported the FCC's general intent of quantifying and managing interference in a more precise fashion. However, in light of the tremendously weak signals observed by passive scientific users of the spectrum, and the long integration times used to make such observations, CORF stated that the use of the interference temperature metric cannot as a practical matter provide the protection needed for scientific observation. Accordingly, CORF strongly recommended that such a metric not be used in bands allocated for passive scientific observation, such as bands allocated to the Radio Astronomy Service or to the Earth Exploration Satellite Service. (April 5, 2004)
Comments In the Matter of United States Spectrum Management Policy For the 21st Century. (NTIA Docket No. 040127027-4027-01). The NTIA asked for comments on a range of issues relevant to spectrum policy reform. CORF supported the propositions that (1) passive scientific use of the spectrum has substantial value that cannot be easily measured in economic terms, so that application of market-oriented allocation and assignment policies to such use is inappropriate, and (2) passive scientific use of the spectrum, which CORF emphasizes is not non-use, is uniquely vulnerable to interference, and protection of such services cannot be based on simple economic factors. (March 18, 2004)
Comments In the Matter of Procedures to Govern the Use of Satellite Earth Stations on Board Vessels in the 5925-6425 MHz/3700-4200 MHz Bands and 14.0-14.5 GHz/11.7-12.2 GHz Bands (IB Docket No. 02-10). CORF discussed the importance to the Radio Astronomy Service (RAS) of observations at 14.47-14.50 GHz and supports the Commission’s proposal, as modified, to protect RAS observations in this band with coordination requirements and with a footnote in the U.S. Table of Allocations. (March 3, 2004, filed late)
Revision of Part 15 of the Commission's Rules Regarding Ultra-Wideband Transmission Systems (ET Docket No. 98-153). CORF opposed the proposal to amend Part 15 rules regarding ultra-wideband (UWB) transmission systems to permit frequency-hopping systems in the 22-29 GHz band. CORF maintained that such systems would pose a significant threat of interference to remote sensing instruments and thus to the important data being gathered by such instruments. (July 16, 2003)
Inquiry Regarding Carrier Current Systems Including Broadband Over Power Line Systems. (ET Docket 03-104) In these Comments, CORF urges the Commission to continue supporting protection of radio astronomy frequencies. Although more information concerning modulation technique, out of band signal strengths, and equipment maintenance is needed for a final evaluation of the impact of broadband over power line systems on other services, CORF is concerned about the possibility of out-of-band, spurious, and harmonic emissions into those bands allocated to radio astronomy, especially from one-wire modulation techniques. (July 7, 2003)
In the Matter of Additional Spectrum for Unlicensed Devices Below 900 MHz and in the 3 GHz Band. In these Comments, CORF urges the Commission not to authorize new transmissions by unlicensed devices on TV Channel 37 (608-614 MHz). The harm to radio astronomy observations by such transmissions would be significant, protection of radio astronomy sites would likely be difficult or impracticable, and there is no evidence that transmissions on Channel 37 are necessary to achieve the Commission's goal of promoting unlicensed services. (April 7, 2003).
In the Matter of Allocations and Service Rules for the 71-76, 81-86, and 92-95 GHz Bands (WT Docket No. 02-146). In these Comments, CORF supports the full enactment of all the allocations proposed in the NPRM, as these allocations constitute a carefully crafted compromise that balances the interests of numerous radio services. Those allocations should be enacted as designated at various World Radio Administrative Conferences (WARCs) and World Radiocommunication Conferences (WRCs), without shifting primary allocations to secondary or unprotected status. While CORF supports coordination between licensed users of these bands and radio astronomy sites, the coordination requirements should be placed in the service rules for the applicable service, not just in the Part 2 Table of Allocations. CORF also notes that work still remains to be done in setting up such coordination procedures. (December 18, 2002).
In the Matter of the 4.9 GHz Band Transferred from Federal Government Use (WT Docket No. 00-32). CONSOLIDATED OPPOSITION TO PETITIONS FOR RECONSIDERATION. The National Academy of Sciences, through the National Research Council’s Committee on Radio Frequencies (hereinafter, CORF), hereby submits its Consolidated Opposition to Petitions for Reconsideration filed by Microwave Radio Communications (MRC) on May 8, 2002, and by the Los Angeles County Sheriff’s Department (LASD) on May 9, 2002, in the above-captioned proceeding. As shown below the Commission’s ban on aeronautical operations in the 4940-4990 MHz (4.9 GHz) band in order to protect radio astronomy observations was proper and follows from the record in this proceeding. However, CORF does not oppose the use of 4940-4950 MHz for aeronautical use, subject to appropriate out-of-band emission protections. Accordingly, the Commission should deny the LASD and MRC petitions as applied to 4950-4990 MHz. (July 1, 2002)
In the Matter of the 4.9 GHz Band Transferred from Federal Government Use (WT Docket No. 00-32). The National Academy of Sciences, through the National Research Council’s Committee on Radio Frequencies (hereinafter, CORF), hereby submits its comments in response to the Commission’s February 27, 2002, Further Notice of Proposed Rulemaking in the above-captioned docket (FNPRM). In these Comments, CORF re-affirms its concern about the potential impact of operations in the 4940-4990 MHz (4.9 GHz) band on radio astronomy observations. Accordingly, rules for operation of such facilities should provide reasonable protection to radio astronomy observations. (July 1, 2002)
In the Matter of Reallocation of the 216-220 MHz, 1390-1395 MHz, 1427-1429 MHz, 1429-1432 MHz, 1432-1435 MHz, 1670-1675 MHz, and 2385-2390 MHz Government Transfer Bands (WT Docket No. 02-08, RM-9267, RM-9692, RM-9797, RM-9854). CORF hereby submits its comments in response to the Commission's February 6, 2002, Notice of Proposed Rulemaking in the above-captioned docket ("NPRM"). In these comments, CORF makes recommendations designed to prevent or limit interference harmful to the research of the users of the Radio Astronomy Service ("RAS") and Earth Exploration Satellite Service ("EESS") who make observations in the 1.4 GHz and 1.6 GHz bands. (March 4, 2002)
In the Matter of Review of Quiet Zones Application Procedures (WT Docket No. 01-319). CORF hereby submits its comments in response to the Commission's November 21, 2001, Notice of Proposed Rulemaking in the above-captioned docket (NPRM). In these comments, CORF supports certain proposals for improvement of coordination between wireless operators and Quiet Zone entities, to encourage early coordination while protecting the current procedural rights of Quiet Zone entities when early coordination is not performed. (January 22, 2002)
[Reply Comments] In the Matter of Allocation and Designation of Spectrum for Fixed-Satellite Services in the 37.5-38.5 GHz, 40.5-41.5 GHz, and 48.2-50.2 GHz Frequency Bands; Allocation of Spectrum to Upgrade Fixed and Mobile Allocations in the 40.5-42.5 GHz Frequency Band; Allocation of Spectrum in the 46.9-47.0 GHz Frequency Band for Wireless Services; and Allocation of Spectrum in the 37.0-38.0 GHz and 40.0-40.5 GHz for Government Operations (IB Docket 97-95, RM-8811). CORF hereby submits its Reply Comments in response to comments filed on the Commission’s May 31, 2001, Notice of Proposed Rulemaking in the above-captioned docket (NPRM). In these Reply Comments, CORF discusses the flaws in comments opposing the Commission’s proposal to provide footnote protection for radio astronomy observations at 42.5-43.5 GHz, and the flaws in comments supporting the allocation of Broadcasting-Satellite Service (BSS) or Fixed-Satellite Service (FSS) downlinks at 42.0-42.5 GHz. (October 3, 2001)
In the Matter of Allocation and Designation of Spectrum for Fixed-Satellite Services in the 37.5-38.5 GHz, 40.5-41.5 GHz, and 48.2-50.2 GHz Frequency Bands; Allocation of Spectrum to Upgrade Fixed and Mobile Allocations in the 40.5-42.5 GHz Frequency Band; Allocation of Spectrum in the 46.9-47.0 GHz Frequency Band for Wireless Services; and Allocation of Spectrum in the 37.0-38.0 GHz and 40.0-40.5 GHz for Government Operations (IB Docket 97-95, RM-8811). CORF hereby submits its Comments in response to the Commission’s May 31, 2001, Notice of Proposed Rulemaking in the above-captioned docket (NPRM). In these Comments, CORF supports the proposal to delete the Broadcasting-Satellite Service (BSS) allocation from the 42.0-42.5 GHz band, supports and provides information regarding the proposed footnote protection of radio astronomy observations in the 42.5-43.5 GHz band, and expresses concern regarding the proposal to add non-government fixed and mobile allocations to the 42.5-43.5 GHz band. (September 4, 2001)
In the Matter of Amendment of Part 2 of the Commission's rules to Allocate Spectrum Below 3 GHz for Mobile and Fixed Services to Support the Introduction of New Advanced Wireless Services, including Third Generation Wireless Systems (ET Docket No. 00-258); Petition for Rulemaking of the Cellular Telecommunications Industry Association Concerning Implementation of WRC-2000: Review of Spectrum and Regulatory Requirements for IMT-2000 (RM-9920); Amendment of the U.S. Table of Frequency Allocations to Designate the 2500-2520/2670-2690 MHz Frequency Bands for the Mobile-Satellite Service (RM-9911). CORF hereby submits its Comments in response to the Commission's January 6, 2001, Notice of Proposed Rulemaking in the above-captioned docket ("NPRM"). In these Comments, CORF supports the proposal in Appendix F (modified as set forth in the filing) of the NPRM to provide protection to certain facilities used in the Radio Astronomy Service ("RAS") against interference from fixed and mobile users in the 1710-1755 MHz band. (March 2, 2001)
In the Matter of Reallocation of the 216-220 MHz, 1390-1395 MHz, 1427-1429 MHz, 1429-1432 MHz, 1432-1435 MHz, 1670-1675 MHz, and 2385-2390 MHz Government Transfer Bands (ET Docket No. 00-221, RM-9267, RM-9692, RM-9797, RM-9854). CORF hereby submits its Comments in response to the Federal Communications Commission’s November 20, 2000, Notice of Proposed Rulemaking in the above-captioned docket. In these Comments, CORF strongly opposes the 1.4 GHz Band Plan Option 3 because both experience and calculations indicate that the allocations proposed therein will be harmful to users of the Earth-Exploration Satellite Service and Radio Astronomy Service ("RAS") who make observations in the 1.4 GHz band. In addition, CORF does not oppose the allocation of the 1670-1675 MHz band to Fixed and Mobile Services (except aeronautical mobile), as long as service rules are enacted that protect important RAS observations in the adjacent 1660-1670 MHz band. (February 16, 2001)
In the Matter of Amendment of the Commission's Rules With Regard to the 3650-3700 MHz Government Transfer Band (WT Docket No. 00-32, ET Docket No. 98-237, RM-9411). CORF hereby submits its comments in response to the Commission's October 24, 2000, Notice of Proposed Rulemaking in the above captioned docket. CORF expresses concern about the potential impact of mobile service operations in the 4.9 GHz band on the Radio Astronomy Service and the Earth Exploration Satellite Service. (December 19, 2000)
In the Matter of The 4.9 GHz Band Transferred From Federal Government Use (WT Docket No. 00-32). CORF hereby submits its comments in response to the Commission's February 26, 2000 Notice of Proposed Rulemaking in the above captioned docket. In these Comments, CORF generally supports the Commission's proposal for re-allocation of the 4940-4990 MHz band. In addition, pursuant to paragraph 18 of the Notice, CORF provides updated information on radio astronomy observatories for the proposed new Footnote US311. (April 26, 2000)
In the Matter of Proceeding to Address Satellite Network Unwanted Emissions (RM-9740). CORF submits comments in response to the Commission’s November 19,1999, Public Notice addressing satellite network unwanted emissions (“Notice”). In these comments, CORF expresses its concern that any relaxation of the unwanted emission limitations in Part 25 of the Commission’s rules would likely have detrimental effects on important observations by radio astronomers and other passive users of the spectrum. CORF therefore urges the Commission to forbear from issuing a notice of proposed rulemaking on these issues, and to take no other action that would weaken satellite unwanted emission limitation standards. (December 20, 1999)
Comments on ET Docket No. 99-261, the Federal Communications Commission's Notice of Proposed Rulemaking in Amendment of Part 2 of the Commission's Rules to Allocate Additional Spectrum to the Inter-Satellite, Fixed, and Mobile Services and to Permit Unlicensed Devices to Use Certain Segments in the 50.2-50.4 GHz and 51.4-71.0 GHz Bands. CORF supports the FCC's NPRM as likely to lead to improvements in the operation of the passive sensors in the Earth-Exploration Satellite Service, and also calls the FCC's attention to the need to protect future space-based radio astronomy from interference in the range 56-62 GHz primarily from inter-satellite service transmissions. (September 30, 1999)
Comments on Docket No. ET 99-255, Amendment of Parts 2 and 95 of the Commission's Rules to Create a Wireless Medical Telemetry Service. CORF comments on an FCC Notice of Proposed Rulemaking to allow medical telemetry devices to operate in bands adjacent to radio astronomy and remote sensing passive bands around 1400-1427 MHz. CORF prefers low-power medical telemetry devices to other possible devices that might be allowed to operate in those bands. (September 30, 1999)
In the Matter of The Establishment of Policies and Service Rules for the Mobile Satellite Service in the 2 GHz Band (ET Docket No. 99-81). CORF asks that the Radio Astronomy Service and the Earth-Exploration Satellite Service operating in the 10.6-10.7 GHz band be protected from out-of-band interference from proposed Mobile Satellite Service feeder downlinks in the neighboring band 10.7-11.7 GHz. The protection level is specified in International Telecommunication Union Radio Regulation 769-1. (June 24, 1999)
In the Matter of Amendment of Parts 2 and 25 to Implement the Global Mobile Personal Communications by Satellite (GMPCS Memorandum of Understanding and Arrangements and Petition of the National Telecommunications and Information Administration to Amend Part 25 of the Commission's rules To Establish Emission Limits for Mobile and Portable Earth Stations Operating in the 1610-1660.5 MHz Band (ET Docket No. 99-67). CORF is asking for protection from interference caused by transmissions from handheld phone transmitters uplinking to satellites. In these Comments, CORF expresses concern about the potentially harmful impact of Global Mobile Personal Communications Service handset uplink transmissions on radio astronomy observations in the protected 1610-1613.8 and 1660-1660.5 MHz bands. CORF also suggests that the Commission prohibit transmissions in the 1660-1660.5 MHz band until sharing rules and coordination mechanisms are established, and that the provisions of Section 25.202(f) or proposed Section 26.216(a) be applied to emissions into that band. (June 21, 1999)
In the Matter of Amendment of Parts 2 and 25 of the Commission's Rules to Permit Operation of NGSO FSS Systems Co-Frequency with GSO and Terrestrial Systems in the Ku-Band Frequency Range, and Amendment of the Commission's Rules to Authorize Subsidiary Terrestrial Use of the 12.2-12.7 GHz Band by Direct Broadcast Satellite Licenses and Their Affiliates (ET Docket No. 98-206). CORF demonstrates that it will be difficult for satellite space-to-Earth downlinks in the 10.7-12.7 GHz band to operate in a manner that does not cause harmful interference to radio astronomy observations in the 10.6-10.7 GHz band, in which the Radio Astronomy Service has a primary allocation. Accordingly, if the Commission allocates use of this band for satellite space-to-Earth downlinks, it must require that such transmissions protect radio astronomy observations at the level required under ITU-R Recommendation RA.769-1. In addition, the Commission should also modify Part 25 of its Rules to provide for a stringent filtering requirement to assure that these levels are met. Such proposed modifications are necessary if radio astronomy observations in this band are to be protected in a meaningful manner. (March 2, 1999)
In the Matter of Amendment of Part 27, 25, and 97 of the Commission's Rules with Regard to the Mobile Satellite Service Above 1 GHz (ET Docket No. 98-142). CORF noted the importance of radio astronomy observations in the 15 and 6.7 GHz bands, and the unique vulnerability of radio astronomy to out-of-band and spurious emissions. CORF asked the FCC to forbear from enacting rules allocating the 15.43 - 15.63 GHz bands, in light of the unfeasibility of sharing between downlinks and RAS in that band, and the resulting likelihood that WRC-00 will modify the allocation to satellite downlinks. Was filed electronically-the first such filing for CORF. (September 29, 1998)
In the Matter of Amendment of Part 27 of the Commission's Rules to Revise Rules for Services in the 2.3 GHz Band and to Include Licensing of Services in the 47 GHz Band (WT Docket No. 98-136). CORF notes the importance of radio astronomy observations in the 42.5 - 43.5 and 48.94 - 49.04 GHz bands, and the unique vulnerability of radio astronomy to out-of-band and spurious emissions. CORF asked the FCC to forbear from enacting spurious and out-of-band emission limits, and from authorizing aeronautical and spaceborne uses of the 47 GHz band, until resolution at WRC-00 of interference standards in that band. If the commission enacts spurious and out-of-band limits at this time, stringent limits are required in order to protect important radio astronomy observations in the 42.5 - 43.5 GHz and 48.94 - 49.04 GHz bands. (September 21, 1998)
Comments on Public Notice in the matter of the WRC-97 Advisory Committee Recommendations for Public Comment (reference no. ISP-96-005). CORF opposes the FCC's proposal to open the bands on either side of the 1400-1427 MHz band for satellite up- and down-links. (June 12, 1997)
Letter to Sky Station International regarding out-of-band emissions on the 48.94-49.04 GHz band allocated to the Radio Astronomy Service (Aug. 19, 1996)
Letter to FCC Chair on ITU-R Task Group 1-3 and Actions Affecting Protection of Radio Astronomy from Spurious Emissions (July 30, 1996)
Comments on 2nd NPRM on Amendment of Parts 2, 15, and 97 of the Commission's Rules to Permit Use of Radio Frequencies Above 40 GHz for New Radio Applications (ET Docket No. 94-124). CORF addressed spurious emission from the third harmonic of millimeter-wave vehicular radars. CORF also filed in a similar matter on January 30, 1995. (May 28, 1996)
Reply Comments in the Matter of Amendment of the Commission's Rules to Establish a Radio Astronomy Coordination Zone in Puerto Rico (May 13, 1996)
Comments in the Matter of Amendment of the Commission's Rules to Establish a Radio Astronomy Coordination Zone in Puerto Rico (ET Docket No. 96-2). CORF filed its comments in support of the need for a coordination zone, and recommended procedures for notification of the Arecibo Observatory, coordination, interference evaluation, and problem resolution. (April 1, 1996)

CORF Filings