EWA Questions Merits of 460-470 MHz Proposal
In Comments filed November 9, EWA joined the LMCC and the National Public Safety Telecommunications Council (NPSTC) in expressing concern about FCC and U.S. support for the World Radiocommunication 2019 Conference (WRC-19) proposal to upgrade satellite overlay operations in the 460-470 MHz band from secondary to co-primary status with respect to terrestrial land-based operations.
On behalf of “the more than 125,000 land mobile systems operating in the 460-470 MHz band,” EWA expressed concern that the power flux density (pdf) limits might not be conservative enough to offer adequate protection. Specifically, EWA worries that the WRC-19 “has not urged adoption of the more stringent pdf level of
-157.8 dBW/m2/4kHz” although elsewhere WRC-19 admits that preliminary “testing by the relevant United States government agencies has shown that, at satellite angles of arrival below 25 degrees, the -152 dBW/m2/4kHz is not adequate to protect terrestrial operations.”
In light of the critical communications conducted within the band, EWA concurred with recommendations made by the LMCC and NPSTC that representatives of these users be involved in testing “to demonstrate that terrestrial operations will be adequately protected before an upgrade” is approved.Category: EWA On Your Side