FCC Sat Service Review Spawns Comments and Concerns
The comment deadline in the FCC Notice of Proposed Rulemaking (NPRM) regarding a comprehensive review of licensing and operating rule for the satellite service ended this week. I covered the NPRM last October in FCC Eyes Video Uplink ATIS Rule Changes. Fourteen comments were filed this week from satellite operators, satellite users industry associations and manufacturers.
Current rules for the automatic transmitter identification system (ATIS) specify transmission of a Morse-code identifier on an analog subcarrier, something that is not practical in all-digital satellite systems. Most geostationary satellite operators or users commented on the ATIS requirements. The FCC proposed two methods for identifying uplinks. One would use the Network Information Table in an MPEG transport stream. The other would use a low-rate data spread spectrum signal with ATIS information. Several commenters felt more information was needed in ATIS, particularly location data.
National Public Radio recommended the first approach, but was not opposed to spread spectrum. NPR said a specific format for the ATIS message was not required, but it supported the FCC's language requiring the message to be submitted in an unencrypted ASCII text format that can be displayed using readily-available computer terminal emulation software. EchoStar said ATIS requirements should only be applied to high-power SNG operations, which it said, “represent the principal threat of harmful interference to satellite operators.” NCTA said ATIS is needed at satellite transmitting facilities, but recommended the FCC defer any action on new ATIS rules until global industry standards currently being worked on are complete. It also cautioned, “should the Commission decide to update its ATIS requirements to conform to standards adopted globally, it should provide satellite uplink operators with a sufficient phase-in period to implement the new requirements.”
For details on the proposed standards and technical data on how a spread spectrum ATIS works, the Comtech EF Data Corporation filing has details.
It also explains the history behind the global effort to implement Carrier ID ATIS: “By 2009, satellite interference had become such an acute problem that satellite industry-wide groups commenced more serious efforts to address it, looking for more efficient and less costly means. These efforts include those of the World Broadcast Union/International Satellite Operators Group ("WBU-ISOG") whose members are primarily video broadcasters, the Radio Frequency Interference End User Initiative ("RFI-EUP) whose members are video broadcasters, satellite operators and equipment manufacturers, and the Satellite Interference Reduction Group ("sIRG") whose members include satellite operators, service providers, video broadcasters, and equipment manufacturers. Comtech EF Data participates in all three of these groups.”
Comtech lists the rules sIRG created for implementation of an improved Carrier ID:
• The identification must be read in the clear, by a properly configured Carrier ID receiver, even if the referenced carrier is encrypted.
• The Carrier ID must be transmitted in an industry accepted format, so as to minimize the number of types of Carrier ID receivers and boost effectiveness.
• The Carrier ID insertion must have a minimal effect on the data carrier overhead, efficiency, Es/No, phase noise and other carrier quality measurements.
The Comtech EF spread spectrum system was tested during the Olympics. Comtech EF's filing reflected this, noting: “More recently, at and for the duration of the 2012 London Olympics, Comtech EF Data, in conjunction tested the superimposition of the Carrier ID signal on video uplink transmissions. Eutelsat, Intelsat and SES placed both the spread spectrum and NIT-based Carrier ID signals on video carriers carrying content from the Olympic Games. There were no reported interference incidents during the Olympics. As explained in the Technical Appendix, there was no reported perceptible degradation in the video uplink signals during the Olympics as a result of the inclusion of the Carrier ID information.”
Comtech EF said that prior to the Olympics (in 2011) numerous tests demonstrated the technology was robust and reliable.
It appears the Comtech EF system may the global standard. Comtech said it “expects the Technical Module will recommend adoption of the spread spectrum Carrier ID specifications consistent with the technology developed and demonstrated by Comtech EF Data as a standard (currently defined as TM-S20108) at its joint Technical Module meeting in mid-January 2013.” The company also expects the specification will be included in the DVB-S2 enhanced next generation standard when that effort is concluded.
Should the spread spectrum/carrier ID technology be adopted by the FCC, SNG and operators will be pleased to know that the technology is available now and can be embedded today in most current commercial satellite modulators.
Engineers for the Integrity of Broadcast Auxiliary Service Spectrum (EIBASS) focused on the impact satellite operations can have on BAS microwave operations in their comments. Key concerns are Mobile Satellite Service (MSS) sharing of the 7 and 13 GHz BAS bands and the 10 GHz FS microwave band. One the conditions of the sharing was that terrestrial BAS operations have to protect MSS downlinks and all possible frequencies and look angles, effectively conveying greater than co-equal status to MSS downlinks with respect to broadcasters' microwaves.
The group commented: “EIBASS submits that it is time to revisit this super-priority given to terrestrial satellite receiving stations. Just as the Commission would not grant a terrestrial point-to-point microwave link on other than immediately needed paths and frequencies, merely because of possible future need, a satellite receive station should only be entitled to protection of downlink frequencies and look angles that are actually used. If a particular satellite fails and the downlink needs to communicate with a different satellite, and thus be protected for a different look angle, then the licensee should have to undertake a new prior coordination notice (PCN) study if a shared band is involved. An engineering STA could be granted for the downlink’s short-term use, while the PCN process is undertaken.”
EIBASS is also concerned about uplinks sharing spectrum with TV BAS not protecting ENG-RO sites, citing an application by ViaSat for a 2 GHz uplink in Duluth, Ga. that was opposed by WGCL-TV. If WGCL-TV had not filed a Petition to Deny the application, EIBASS said it “has little doubt it would have been granted.”
I've only covered the comments that are likely to have an impact on broadcast stations and satellite users. Satellite operators filed comments requesting more flexibility in non-substantial satellite relocation or beam positioning. These comments can be found at the link provided earlier.