58TH ANNUAL CONFERENCE, Conchal, Costa Rica, 20-24 May 2019Agenda Item: B.5.3 – WP No. 88Review of Radio Frequency Spectrum Protection PolicyPresented by TOC |
Summary
Since the last IFATCA paper on Radio Frequency Spectrum Protection in 2002, many of the same issues remain, but may have been amplified by growth so the information bears repeating and updating. The world of ITU Radio Regulations is a very competitive one wherein the aviation community should not expect special treatment.
Introduction
1.1. Technology and economics have placed increasing demands on the finite resource of spectrum. As a result of increased demand for bandwidth there is a need to be the most responsible stewards of the spectrum. Even if current air traffic demands can be consolidated, that does not factor in the future technologies that are in development. As a result, it is vital to maintain access to the spectrum allotted to aviation.
1.2. Through the years, aviation has had consistent and reliable access to ample spectrum for its needs. As aviation and other sectors grow and place increasing demand on the limited resource of spectrum there is an increasing need for more efficient utilization.
1.3. One of the causal factors for this paper is the current issue of PMSE (Programme Making and Special Events) utilization in the UK which most commonly presents with digital wireless microphones; wherein the aeronautical spectrum would be shared. This raises concerns of unforeseen consequences of PMSE and similar technology integration.
1.4. “The radio-frequency spectrum is a non-depletable but limited natural resource available in all countries and in outer space.” This quote from the ITU (International Telecommunications Union) best summarizes the importance of managing and protecting the radio spectrum.
1.5. The world of ITU Radio Regulations is a competitive one wherein the aviation community should not expect special treatment; in such an environment, the only way to promote the needs of our aviation community is to be a well-educated advocate.
1.6. Any alteration to access should only be done with extensive and continuous analysis with many checks. Further any access granted to the aviation spectrum should be adapted to the needs and requirements of aviation.
1.7. The dynamic adjustments to ITU Radio Regulations are especially vital as SARPS can take a lengthy period to be created.
Discussion
2.1. Aviation frequencies are a vital part of the functioning of the air traffic management system beyond just voice communications; the variety of impacted systems include ADS-B, CPDLC, SSR, TCAS, radio altimeters, and DME. Of which some of the most concerning are the frequencies being shared by the PMSE bands which include TCAS, SSR, DME and ADS-B.
2.2. ICAO formed the FSMP (Frequency Spectrum Management Panel) in 2015 to ensure communication and navigation would continue to be safely provided. IFATCA does not have a member on the FSMP. The panel communicates the needs of ICAO to the ITU and works to create ICAO policy on Radio Frequency Spectrum.
2.2.1. Several papers were presented at the FSMP meeting in February 2018 including one detailing important methodology for managing allocation titled Spectrum Management Process. Once the finite resource of frequency allocation is spent there may be a need to share spectrum in the future. There are some necessary steps to follow to ensure this is properly handled, including following the current ICAO documents, transparency of process, justifications, and understanding of the implications and consequences. Within the document there is a detailed flow chart to be used in the decision-making procedure.
2.2.2. The most recent FSMP meeting was held 21-29 January 2019 during which some crucial issues were covered such as Programme Making and Special Events (PMSE), review of some of the ITU Radio Regulations for current and future utilization, and Aeronautical protection criteria (VHF communications). The next meeting of the FSMP is scheduled for 22-30 August 2019.
2.3. Further guidance regarding frequency allocation can be found in the Handbook on Radio Frequency Spectrum Requirements for Civil Aviation including statement of approved ICAO policies (Doc 9718). Contained within this document is the ICAO Spectrum Strategy. This section highlights many key points including the extensive testing necessary if an ANSP were to share spectrum with a non-aviation user.
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8.2.1 Purpose of the ICAO spectrum strategy 8.2.1.1 The safety aspects on the use of radio frequency spectrum by aviation require spectrum to be available on an exclusive basis or, when shared with non-aeronautical radio services, with regulatory and technical conditions that recognize aeronautical safety requirements. The overall ICAO spectrum policy Handbook on Radio Frequency 8-2 Spectrum Requirements for Civil Aviation includes the ICAO spectrum strategy presented here and the ICAO policy statements contained in Chapter 7. Both the spectrum strategy and the policy statements are approved by the ICAO Council. 8.2.1.2 Implementation of the spectrum strategy will enable the advancement of technological developments and innovation to enhance safe and efficient global air transport. This is to be achieved through the development of ICAO SARPs as necessary. 8.2.1.3 The radio frequency spectrum capacity for aviation must be sufficient to meet the growing needs for aeronautical communication, navigation and surveillance systems, including any new systems that are being considered in ICAO to meet future CNS/ATM requirements. This is essential to adequately support changing trends in air traffic management such as foreseen in the GANP and the ICAO Regional Plans. 8.2.1.4 Spectrum for aeronautical radiocommunication and radionavigation (including surveillance) is allocated by the ITU with the recognition of the safety aspects identified above. The ICAO spectrum policy aims to ensure that aeronautical spectrum capacity requirements are satisfied during the frequency allocation process, taking into consideration the trends in future air traffic management |
(ICAO Document 9718, Vol 1, 8.2.1)
2.3.1. ICAO, within Doc 10075 (Assembly Resolutions in Force), emphasizes the importance of stakeholders acting in compliance with the agreements reached by the WRC and other ICAO documents.
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1. Urges Member States, international organizations and other civil aviation stakeholders to support firmly the ICAO frequency spectrum strategy and the ICAO position at WRCs and in regional and other international activities conducted in preparation for WRCs, including by the following means: a) working together to deliver efficient aeronautical frequency management and “best practices” to demonstrate the effectiveness and relevance of the aviation industry in spectrum management; b) supporting ICAO activities relating to the aviation frequency spectrum strategy and policy through relevant expert group meetings and regional planning groups; 2. Requests the Secretary General to bring to the attention of ITU the importance of adequate radio frequency spectrum allocation and protection for the safety of aviation; 3. Instructs the Council and the Secretary General, as a matter of high priority within the budget adopted by the Assembly, to ensure that the resources necessary to support the development and implementation of a comprehensive aviation frequency spectrum strategy as well as increased participation by ICAO in international and regional spectrum management activities are made available; and 4. Declares that this resolution supersedes Resolution A36-25. |
(ICAO Doc 10075 Assembly Resolutions in Force (as of 6 October 2016))
2.4. In October 2018 ICAO had the 13th AN-Conf wherein a working paper was presented emphasizing the importance of efficiency in spectrum use. One issue that will impact aviation spectrum in the future is the financial situation surrounding both short and long term goals. Resources, both financially and in terms of human effort, are required to continue to proactively evolve aeronautical Communications, Navigation and Surveillance (CNS) systems for the long term.
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Recommendation 2.2/1 — Long-term evolution of communication, navigation and surveillance systems and frequency spectrum access That States: a) engage in the spectrum regulatory process to ensure the continued necessary access to and protection of safety-critical aeronautical communications, navigation, and surveillance (CNS) systems; b) ensure through the implementation of a safety oversight programme that the designated competent authorities are involved in safety case assessments of the radio frequency environment so as to adequately protect the operational availability of aeronautical CNS systems; That ICAO: c) launch a study, built on a multidisciplinary view of the C, N and S elements and frequency spectrum, to evolve the required CNS and frequency spectrum access strategy and systems roadmap in the short, medium and long term, in a performance-based and service-oriented manner, to ensure that CNS systems remain efficient users of the spectrum resource; and |
2.4.1. The Global Air Navigation Plan (GANP) is laid out within ICAO Doc 9750. The document features the Basic Building Blocks (BBBs) of technology to make way for future innovations and incorporation. In order to allow these future technologies, which could allow for increases in safety and capacity while helping mitigate controller workload, there is a necessity for the spectrum availability. When planning for future technology it can be difficult to predict exactly how much of and the bands which may need to be utilized so maintaining the most variety allows for more eventualities.
2.5. It is a concern for the aviation community that radio frequencies from the aviation reserved spectrum are being utilized for non-aviation applications. IFATCA policy is valid and solid and is of the opinion that this utilization should be thoroughly studied before allowing interests outside of aviation access could even be considered. Radio spectrum is a finite resource that is experiencing an ever-increasing demand for its use and must be protected for both current and future aviation uses. The paramount issue remains that States are informed of the potential issues associated with insufficient protection of reserved sections of the radio spectrum.
2.5.1. IFATCA has existing policy on Radio Frequency Spectrum Protection Policy, ATS 3.12:
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The radio-frequency spectrum must be managed in a manner that at all times ensures the safety of current aviation activity and allows for future safety-of-flight applications. Existing spectrum allocations for exclusive aviation use must not allow other uses until it is thoroughly proven that aviation safety will not be compromised by the shared use of the spectrum allocation. Prior to aviation use of shared spectrum allocations, it must be thoroughly proven that safety-critical aviation requirements are not compromised. Adequate protection against harmful interference to aviation spectrum use must be ensured. |
(IFATCA. (2018). TPM, 2018 Ed., ATS 3.12)
2.5.2. The policy still holds true with frequency spectrum use needing to ensure safety of flight in both current and future versions of air traffic services. It is important to consider that we may need to budget for future technology that does not exist yet. This can also be done in part by maintaining current access and being mindful stewards of what we do have.
2.5.3. As aviation technology advances and additional equipment is developed and implemented the demand on existing infrastructure grows. Since the publication of the IFATCA working paper in 2002, there have been marked increases in areas such as datalink and related technologies, UAS, etc. These developments show no sign of slow down. We must be forward-thinking to preserve frequency spectrum since it is a finite resource.
2.5.4. Prior to utilizing aviation-exclusive bands for other uses thorough studies should be completed with an emphasis on safety management. As the numbers of users demanding access to the spectrum increases, the need for a safe protocol for allocation is vital.
2.6. Other aviation organizations, such as International Air Transport Association (IATA), align their viewpoints with those of ICAO FSMP.
2.7. The International Telecommunications Union (ITU) is an agency under the United Nations (UN) which handles information and communication technology. The ITU is responsible for many matters including the allocation of spectrum and associated technical standards. Every three to five years the ITU hosts the World Radiocommunications Conference (WRC), during which radio regulations are discussed. Among the tasks undertaken at this meeting is maintaining a table of frequency allocation; as such, there is a need for aviation frequency managers to continue to lobby on behalf of aviation.
2.7.1. Article 4.10 of Radio Regulations states: Member States recognize that the safety aspects of radionavigation and other safety services require special measures to ensure their freedom from harmful interference; it is necessary therefore to take this factor into account in the assignment and use of frequencies.
Every state has a role to play in continued worldwide spectrum protection.
2.7.2. ITU has 3 spectrum management study groups specializing in areas including engineering, management methodologies and monitoring.
2.7.3. Since the initial IFATCA paper in 2002 the ITU has continued to meet regularly and their radio communication subdivision has been producing papers including additional research on aviation frequency spectrum management.
2.7.4. The ITU has been laying out legal principles within the ITU Constitution including:
| a) “while fully recognizing the sovereign right of each State to regulate its telecommunication…” (ref CS-1), “… to avoid harmful interference between the radio stations of different countries” ref CS-11);
b) “… to improve the use made of the radio-frequency spectrum for radiocommunication services and of the geostationary-satellite and other satellite orbits” (ref CS-12); c) to “facilitate the worldwide standardization of telecommunications, with a satisfactory quality of service” (ref CS-13), and “… to harmonize the development of telecommunication facilities, … with a view to full advantage being taken of their possibilities” (ref CS-15); d) to “foster international cooperation and solidarity …” (ref CS-14). |
2.7.5. Some highlights of the ITU Radio Regulations (RR) include the ability to help facilitate an equitable access to both the radio frequency spectrum and geostationary satellites.
2.7.6. The ITU has produced a document on Guidance of Regulatory Framework for National Spectrum Management. There is an emphasis on multinational agreements to preserve the functionality of the spectrum.
2.7.7. The ITU discusses the differences that may be faced in spectrum protection due to legal structure of the system in different States:
| 2.3.2 Legal framework, regulation
In some countries (France, Switzerland, etc.), the legislation regulating telecommunications network and services organizes spectrum management. In some other countries (United Kingdom, Japan, Australia, India, Korea, etc.), there is in addition a radiocommunications act that covers all aspects of radiocommunications and often precedes telecommunication legislation. The ITU-R Handbook on National Spectrum Management (2005) recommends the adoption of a radiocommunications act. The radio-frequency spectrum is a shared resource and its use must be legally framed, especially when market forces influence spectrum management. Spectrum management (planning) should be a prerequisite for licences/authorizations (regulation of the telecommunications and audiovisual markets). |
2.7.8. Some of the results of WRC 2015 include Global Aeronautical Distress & Safety System (GADSS) obtaining new allocations for ADS-B, better regulations for both fixed and satellite service for VSAT within Africa and the Indian Ocean, and new regulations for UAS.
2.7.9. Some key elements of the 2019 upcoming conference include spectrum allocation for selected services utilizing broadband, regulatory harmonization of Global Aeronautical Distress and Safety System, and regulations for space services.
2.7.10. ICAO has produced a position paper for ITU WRC 2019 which details some of the matters to be covered in forthcoming meetings. Among their concerns remains aviation frequency spectrum protection. Air traffic safety is currently reliant on available access to reliable radar, navigation and communication methods’ and will continue to be in the future. There are also plans to incorporate technologies such as UAS. While some of the needs of UAS are met with better utilization of current spectrum there may be a need for an increased number of bands as their numbers inevitably climb.
2.8. Additional regulations can be found on regional and national levels. This includes EU laying out the acceptable levels of safety performance needed; these regulations are detailed within COMMISSION IMPLEMENTING REGULATION (EU) 2017/373.
2.8.1. The European Conference of Postal and Telecommunications Administrations (CEPT) was founded in 1959 and deals with cooperation through regulations, commercial and operational issues as well as technical standardization. CEPT has, under its European Communications Committee (ECC) umbrella has the Working Group Frequency Management (WG FM).
2.9. There have been marked increases in worldwide air traffic in both manned and unmanned aircraft. Since 1970 there have been average annual increases of 4.5%, which amounts to a doubling every 15 years, with no sign of slow down. The ability for air traffic to continue is reliant on continued access to appropriate available spectrum.
2.10. Efficient use of the spectrum should be employed by ANSPs. This demonstrates good stewardship of this limited resource. Further it allows for space to allot to future needs.
2.10.1. As with many matters, being prepared and identifying issues allow for challenges to be identified early and resolved. In the same breath, maintaining current spectrum levels for future even if there is ability for more efficient use allows for flexibility.
2.10.2. Within the ICAO Handbook on Radio Frequency Spectrum Requirements for Civil Aviation (Document 9718) there are concerns about the desirability of the spectrum to non-aviation interests particularly in the 960-1164 MHz range. The document also states that the accommodation of these non-aviation users can likely not be supported.
2.10.3. A 2013 study regarding the 1030 and 1090 MHz spectrum bands including their importance and the potential for future overload. The spectrum in areas of high density traffic is already pushing maximum capacity. This saturation of data could lead to systems such as surveillance and ACAS performing below their desired levels. This data capacity issue is not new. By 2011 some sites were nearing limiting values during peak traffic. This does not yet factor in the growth of the aviation system since that time as well as moving forward. There are also concerns about how reaching and exceeding these values could impact controllers due to slower replies or lost information.
2.11. The lifecycle of aviation technology happens more slowly than other technologies, such as cellular telephones. Due to the critical nature of the aviation spectrum there are many layers of safety that any new technology must comply with before even being considered. There is also the need to verify compatibility with existing or new infrastructure to ensure any changes are seamless.
2.12. A future method to assist with frequency spectrum is IP connectivity to aircraft utilizing both ground and satellite-based systems. These matters must be RTCA (Radio Technical Commission for Aeronautics) compliant. RTCA SC-223 is actively working toward building standards for IP which would allow for increases in bandwidth availability.
2.12.1. As future technologies are developed there could be a reduced need for radio spectrum bandwidth. This may arise through digital connectivity which would utilize the spectrum but in different ways. Not knowing what new concepts may arise we must be cautious with how we disperse and consider sharing our spectrum.
2.12.2. Available space on the spectrum is needed for potential modernization including advances in cyber security and the inevitable increases in space based operations.
2.13. Future concerns include the potential of sharing or selling of vital pieces of the aviation radio spectrum. These steps could be the first of a slippery slope of continual grabs for aviation spectrum by outside users.
2.13.1. The United States has started preliminary studies across multiple agencies, including the Federal Aviation Administration (FAA), to release 30 MHz of the 1300-1350 MHz bands for non-aviation, non-federal use. This part of the spectrum is associated with radar display including aircraft and weather radar. The goal is to release these bands for auction in 2024 pending feasibility studies. This section of the spectrum could bring the US government in upwards of 19 billion USD for the sale. Part of the reasons the US government cited for the consolidation, aside from potential financial incentives, are the streamlining of data across agencies utilizing them. Within the bands that are seeking consolidation is legacy surveillance data, which includes aircraft and weather radar.
2.14. An issue that has arisen in the United Kingdom is aviation spectrum being shared with non- aviation spectrum in the use of PMSE. PMSE is described within ECC Report 204 as “The term Programme Making and Special Events applications (PMSE) describes radio applications used for SAP/SAB, ENG/OB and applications used in meetings, conferences, cultural and education activities, trade fairs, local entertainment, sport, religious and other public or private events for perceived real-time presentation of audio/visual information.” Utilization of PMSE equipment is only forecasted to rise as increasing numbers of people access information.
2.14.1. PMSE equipment would be sharing the 960-1164mHz bands, which are utilized in aviation spectrum. The part of the spectrum that this effects is the portion including TCAS, SSR, DME and ADS-B. Knowing that PMSE is already being utilized there are many concerns including the unknown quality of some of the equipment that would be sharing the aviation bands. As more equipment is brought in from different vendors of potentially varied levels of quality, it can raise the risk of danger in the system. There may be no or limited regulations in place to ensure the quality of these products used in PMSE equipment.
2.14.2. A test was run in 2017 titled “Coexistence of PMSE with Aeronautical Services in the Band 960- 1164MHz”, wherein PMSE units were tested to see if they impacted transponders and interrogators within the approved operations range. PMSE units were tested against 2 DME transponders and interrogators from different manufacturers. ICAO Annex 10 states that the beacon must maintain at least 70% reply efficiency. Of which one of the more concerning results was both ground beacons were susceptible to returns of lower than 70% when encountering a pulse from PMSE.
2.14.3. During the most recent FSMP meeting in January 2019 PMSE was a topic discussed intensively. Topics included work being studied at the CEPT level for using lower power PMSE, final research forthcoming in summer 2019. Before publication there will be a period of public commentary including non-European stakeholders. A joint study was also presented with the UK CAA and Ofcom, one of the outcomes of which was PMSE having to adapt for future changes in aeronautical band use.
2.14.4. Currently the UK is the only example for the attempt to share the dedicated aeronautical spectrum.
2.14.5. The PMSE matter is further complicated in that the technology can easily be exported. Further adding complexity is that the strength of which the radio technology used could be altered. Knock off units could easily be produced and utilized outside of the prescribed regulatory procedures.
2.15. Before releasing parts of the spectrum to other entities, either entirely or to be shared, extensive safety checks are required. Both of these matters introduce additional risk to the system. Releasing aviation spectrum to other entities could result in not having availability to integrate later technology. Sharing spectrum with non-aviation users include problems such as bleed over, when there is a disruption due to simultaneous broadcast on the same frequency.
2.16. In the event of interference there is the challenging question of liability. Would the problem fall to the outsider causing the interference or the State for allowing the situation to be set up in a way that it was a possible risk?
2.17. The most important goal is to spread awareness among member associations of the importance of intensive studies before allowing reallocation of frequencies. If frequencies are shared or sold to non-aviation entities, the complexity level to reallocate them later could be very difficult.
Conclusions
3.1. States should seek to be the good stewards of the available frequencies that are allotted. There are risks inherent with choosing to share aviation spectrum with non-aviation users. Complications may also arise from releasing spectrum to other entities, such as bleed over and difficulty stringently maintaining quality of non-aviation users’ equipment.
3.2. In order to provide for the support of current technologies and the development of future systems, it is vital to maintain access to frequency spectrum. This is especially vital in the vital 1090 MHz spectrum band which in some areas is reaching maximum capacities.
3.3. The goals of the original policy remain the same, for MAs to act in methods that protect aviation spectrum for current and future uses. There are continued concerns of States reallocating their aviation frequencies for other commercial uses. Before this is considered, extensive safety-centric testing should be conducted.
Recommendations
4.1 It is recommended that:
IFATCA encourages the development of technology which utilizes the frequency spectrum more efficiently.
is appended to existing policy ATS 3.12 Aviation Radio Frequency Spectrum in the IFATCA Technical and Professional Manual.
References
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Last Update: October 2, 2020