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CORF Filings

August 26, 2013
Comments In the Matter of Expanding Access to Broadband and Encouraging Innovation through Establishment of an Air-Ground Mobile Broadband Secondary Service for Passengers Aboard Aircraft in the 14.0-14.5 GHz Band (GN Dkt. 13-114; RM-11640). 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 May 9, 2013 Notice of Proposed Rulemaking (NPRM) (FCC 13-66) in the above-captioned docket, regarding a bi-directional Air-Ground Mobile Broadband Service (AMS) at 14.0 to 14.50 GHz. In light of the importance to the Radio Astronomy Service (RAS) of observations at 14.47 to 14.50 GHz, CORF recognizes the importance of sharing spectrum among different services where feasible, but notes that an aeronautical service transmitting down to Earth in this band could cause significant interference problems for RAS facilities. CORF recommends that if a new bidirectional service is established in the 14.0-14.5 GHz band, that the 14.47-14.50 GHz portion be limited to uplink (ground-to-air) transmission. In any case, careful consideration of and commitment to solutions, including addressing issues regarding coordination and emission levels, must be made should this new service be authorized.

May 7, 2013
Comments in the Matter of Amendment of Parts 1, 2, 15, 74, 78, 87, 90, and 97 of the Commission’s Rules Regarding Implementation of the Final Acts of the World Radiocommunication Conference (Geneva, 2007) (WRC-07), Other Allocation Issues, and Related Rule Updates (ET Docket No. 12-338).  The National Academy of Sciences, through the National Research Council's Committee on Radio Frequencies (hereinafter, CORF), hereby submits its Reply Comments in response to the Commission's November 19, 2012, Notice of Proposed Rulemaking in the above-captioned docket (NPRM).  In these Comments, CORF briefly addresses two proposals in the NPRM to relax the recommended levels of unwanted emissions into the 22-23 and 31 GHz passive service bands. CORF does not oppose the Commission’s clarification regarding 22-23 GHz inter-satellite links, but does oppose the proposal regarding limits on unwanted emissions for fixed stations transmitting in the 31-31.3 GHz band.  CORF also addresses elements of the Commission’s proposals regarding power and elevation angles in the 10.6-10.68 GHz band.

January 25, 2013
Comments in the Matter of Expanding the Economic and Innovative Opportunities of Spectrum Through Incentive Auctions (Docket No. 12-268).  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 October 2, 2012, Notice of Proposed Rulemaking in the above-captioned docket (NPRM).  In these Comments, CORF discusses the nature of observations by the Radio Astronomy Service (RAS) in the 608-614 MHz band (i.e., Channel 37) and the remainder of the television band (TV Band).  CORF urges the Commission to maintain a protected band for RAS observation of red-shifted hydrogen and other astrophysical phenomena, either at Channel 37 or in another TV Band channel (such as TV Channel 4).  CORF has significant concerns about the Commission’s proposal to allow operation of unlicensed “white space” devices on Channel 37, but if such devices are allowed to operate on Channel 37 (or on another channel allocated to the RAS), then the Commission should protect certain RAS facilities by prohibiting operation of white space devices in areas surrounding those RAS facilities.  Last, it is essential that the Commission be mindful of out-of-band emission rules for wireless broadband downlinks in any channel allocated next to a channel allocated to the RAS.

October 1, 2012
Comments in the Matter of Amendment of Part 90 of the Commission’s Rules (WP Docket No. 07-100) Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHz Band (PS Docket No. 06-229) Service Rules for the 698-746, 747-762 and 777-792 MHz Bands (WT Docket No. 06-150).  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 Fifth Further Notice of Proposed Rulemaking (FCC 12-61) in the above-captioned dockets (FFNPRM).  In these Comments, CORF discusses the proposed new rules for aeronautical mobile use of spectrum at 4940-4990 MHz (4.9 GHz band) and the potential interference impact on Radio Astronomy Service (RAS) observations in that band.  CORF recognizes that communications technologies are critical to maintaining and improving public safety, and CORF has long supported the thoughtful sharing of spectrum among services, when such sharing is practical.  However, as recognized in footnotes to the FCC’s Table of Allocations, an aeronautical service transmitting down to Earth is the worst-case scenario in regard to potential interference problems for RAS facilities.  Nevertheless, CORF does not oppose lifting the general prohibition on aeronautical use of the 4.9 GHz band, as long as the Commission enacts all of the proposed protections for the RAS in the FFNPRM, that is, that any new rules for aeronautical use in this band should (1) make the aeronautical use secondary to terrestrial services, including the RAS; (2) limit the altitude of use of this band to 1,500 feet above the altitude of the observatory and limit operation to greater than 50 miles from observatories operating at this frequency or otherwise prevent line-of-sight transmissions to RAS facilities; (3) require applicants to demonstrate that the proposed aeronautical use will protect from interference RAS observatories within the threshold distance from the edge of aeronautical operations; and (4) require applicants to certify that they have served a copy of their application to any RAS observatories within that threshold distance.   

July 25, 2012
Comments in the Matter of Utilizing Rapidly Deployable Aerial Communications Architecture in Response to an Emergency (PS Docket No. 11-15).  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 May 24, 2012, Notice of Inquiry (FCC 12-53) (NOI) in the above-captioned docket regarding Deployable Aerial Communications Architecture (DACA).  In these Comments, CORF expresses support for exploring the use of DACA technologies to facilitate emergency response in the immediate aftermath of a catastrophic event.  CORF notes, however, that in evaluating frequency planning and minimizing the potential for harmful interference, consideration must be given to passive scientific use of the spectrum.  Indeed, some passive scientific uses of the spectrum might help to mitigate the effects of some natural disasters.

July 16, 2012
Comments in the Matter of Amendment of the Commission’s Rules to Establish a Next-Generation Air-Ground Communications Service on a Secondary Licensed Basis in the 14.0 to 14.5 GHz Band (RM-11640).  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 May 15, 2012, Public Notice (DA 12-767) in the above-captioned docket, regarding a Petition for Rulemaking filed by Qualcomm to establish an air-to-ground mobile service at 14.0 to 14.50 GHz (Petition).  In these Comments, CORF discusses the importance to the Radio Astronomy Service (RAS) of observations at 14.47 to 14.50 GHz.  CORF recognizes the importance of sharing spectrum among different services where feasible, but notes that an aeronautical service transmitting down to Earth in this band could cause significant interference problems for RAS facilities.  Qualcomm has properly proposed that operators of such a new aeronautical service be required to enter into coordination agreements to protect RAS facilities.  However, as discussed below, such coordination will likely be considerably more challenging than coordination with the RAS by other commercial users of this band, such as operators of aeronautical mobile satellite services.  Accordingly, careful consideration of and commitment to solutions will be essential if this new service is authorized.  

May 23, 2012
Comments in the Matter of Amendment of Part 15 of the Commission’s Rules to Establish Regulations for Tank Level Probing Radars in the Frequency Band 77 81 GHz and Amendment of Part 15 of the Commission’s Rules to Establish Regulations for Level Probing Radars and Tank Level Probing Radars in the Frequency Bands 5.925 7.250 GHz, 24.05 29.00 GHz and 75 85 GHz.  The National Academy of Sciences, through the National Research Council's Committee on Radio Frequencies (hereinafter, CORF; see appendix), hereby submits its comments in response to the Commission's March 26, 2012, Further Notice of Proposed Rulemaking in the above-captioned docket (FNPRM).  In these comments, CORF discusses the importance to the Radio Astronomy Service (RAS) of observations in the 75-85 GHz band, the vast majority of which is allocated to the RAS on a primary basis.   CORF does not oppose the sharing of spectrum in this band with a service permitting level probing radars (LPRs), subject to the protections proposed in the FNPRM.  CORF suggests, however, that in order to facilitate resolution of any possible interference issues with RAS observatories, that manufacturers of LPR equipment also be required to maintain a database with information on the purchasers of such equipment, and to place that information in a publicly accessible database.

February 27, 2012
Reply Comments in the Matter of Amendment of the Commission's Rules to Permit Radiolocation Operations in the 78-81GHz Band (WT Docket No. 11-202) and  Request by the Trex Enterprises Corporation for Waiver of Section 90.103(b) of the Commission's Rules (RM-1 1612).  The National Academy of Sciences, through the National Research Council's Committee on Radio Frequenciesl (hereinafter, CORF), hereby submits its Reply Comments in response to the Commission's December 20,2011 Notice of Proposed Rulemaking (NPRM), in the above-captioned docket. In these Reply Comments, CORF discusses the importance to the Radio Astronomy Service (RAS) of observations at 78-81 GHz, and notes that it does not oppose sharing of spectrum in this band with a service permitting fixed radars at airports to monitor foreign object debris (FOD). CORF suggests, however, that such a service be a licensed one, with a requirement for coordination with certain RAS facilities. A coordination requirement should not be a significant burden on the operators of such radars, given the limited number of radio astronomy facilities that observe in the 78-81 GHz band, and the ease with which any potential inteference could be mitigated.

August 4, 2011
Comments in the matter of Amendment of Sections 15.35 and 15.253 of the Commission’s Rules Regarding Operation of Radar Systems in the 76-77 GHz Band (ET Docket No. 11-90) and Amendment of Section 15.253 of the Commission’s Rules to Permit Fixed Use of Radar in the 76-77 GHz Band (ET Docket No 10-28).  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 May 25, 2011, Notice of Proposed Rulemaking (NPRM), in the above-captioned docket.   In these comments, CORF discusses the importance to the Radio Astronomy Service (RAS) of observations at 76-77 GHz and notes that it does not oppose sharing of spectrum in this band to permit fixed radars at airports for monitoring the movement of terrestrial vehicles, as set forth in the NPRM.  However, in light of the primary allocation of this band to the RAS, CORF believes that rules increasing the average power density limit for automotive vehicular radars operating in this band should not be considered unless radar manufacturers are required to work with representatives of the RAS community to minimize interference with RAS observations. 

February 7, 2011
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 Frequency Band for Government Operations (IB Docket No. 97-95).  The National Academy of Sciences, through the National Research Council's Committee on Radio Frequencies, hereby submits these Reply Comments in response to the Commission's Notice of Proposed Rulemaking in the above-captioned docket (FCC 10-186).  Herein, CORF notes the importance of protecting Radio Astronomy Service users in the 42.5-43.5 GHz band from out-of-band interference and addresses relevant filed comments.

August 12, 2010
Reply Comments ln the Matter of Office of Engineering and Technology Request for lnformation on Use of 1675-1710 MHz Band (ET Docket No. 10-123).  The National Academy of Sciences, through the National Research Council's Committee on Radio Frequencies (hereinafter, CORF), hereby submits these comments in response to the Commission's June 4, 2010, Public Notice in the above captioned docket (ET 1 0-123) seeking comments on the use of the 1675-1 710 MHz band.

November 5, 2009
Reply Comments In the Matter of Fostering Innovation and Investment in Wireless Communications Market (GN Docket No. 09-157) and A National Broadband Plan for Our Future (GN Docket No. 09-5).  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 August 27, 2009, Notice of Inquiry in the above-captioned dockets (NOI).  CORF notes that the initial comments in response to the NOI did not address the passive scientific use of the spectrum.  Thus, CORF discusses herein the unique value, innovation and vulnerability of passive scientific use of the spectrum, and the impact on issues of interference protection and spectrum efficiency raised in the NOI.

July 21, 2009
Reply Comments In the Matter of A National Broadband Plan for Our Future (GN Docket No. 09-51).  The National Academy of Sciences, through the National Research Council's Committee on Radio Frequencies (hereinafter, CORF ), hereby submits its reply comments in response to the Commission's April 8, 2009, Notice of Inquiry in the above-captioned docket (NOI).  Herein, CORF addresses issues raised in paragraph 44 of the NOI regarding a proposed “spectrum inventory” and discusses the need to recognize and protect the passive scientific use of the spectrum in connection with any such inventory.  CORF also addresses the potential impact of cognitive radio technologies on passive scientific use of the spectrum.

August 16, 2007
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 13, 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.


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, 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.


December 6, 2006
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.


June 30, 2005
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.


May 26, 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.


September 1, 2004
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.


May 3, 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.


April 5, 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.


March 18, 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 3, 2004 - filed late
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.


July 16, 2003
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 7, 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.


April 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.


December 18, 2002
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.


July 1, 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.


March 4, 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.


January 22, 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.


October 3, 2001
[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.


September 4, 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.


March 2, 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.


February 16, 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.


December 19, 2000
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.


April 26, 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.


December 20, 1999
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.


September 30, 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.


June 24, 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 21, 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.


March 2, 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.


September 29, 1998
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 21, 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.


June 12, 1997
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.


August 19, 1996
Letter to Sky Station International regarding out-of-band emissions on the 48.94-49.04 GHz band allocated to the Radio Astronomy Service


July 30, 1996
Letter to FCC Chair on ITU-R Task Group 1-3 and Actions Affecting Protection of Radio Astronomy from Spurious Emissions


May 28, 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 13, 1996
Reply Comments in the Matter of Amendment of the Commission's Rules to Establish a Radio Astronomy Coordination Zone in Puerto Rico


April 1, 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.      
 

 

February 7, 2011
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 Frequency Band for Government Operations (IB Docket No. 97-95).  The National Academy of Sciences, through the National Research Council's Committee on Radio Frequencies, hereby submits these Reply Comments in response to the Commission's Notice of Proposed Rulemaking in the above-captioned docket (FCC 10-186).  Herein, CORF notes the importance of protecting Radio Astronomy Service users in the 42.5-43.5 GHz band from out-of-band interference and addresses relevant filed comments.

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