CNS Systems - Navigation, Spectrum & Surveillance National Air Traffic Services Ltd
Spectrum House, Gatwick, West Sussex, RH6 OLG
Direct Tel: +44 (0)1293 576595 Direct Fax: +44 (0)1293 576431 Switchboard: +44 (0)1293 576000 E-Mail:
stephen.parry@natsnav.co.uk www.nats.co.uk
12" April 2002
Mr Paul Redwin
Radiocommunications Agency
10B/20B, Licensing Policy Unit
Wyndham House
189 Marsh Wall
London E14 9SX
Dear Mr Redwin,
Response to RA Consultation.
I enclose a copy of the response of National Air Traffic Services Ltd to the RA consultation on the disclosure of
wireless telegraphy licence information on radio frequency and assignment use that was issued in January 2002.
Yours sincerely,
Stephen Pany
Spectrum Management & Safeguarding
National Air Traffic Services Ltd. Registered in England 3155567 Registered Office: One Kemble Street, London
WC28 4AP
National Air Traffic Services Ltd response to the
Radiocommunications Agency consultation document on the
disclosure of wireless telegraphy licence information on radio
frequency and assignment use
12th April 2002
National Air Traffic Services Ltd (NATS) welcomes the opportunity to respond to the consultation document on the
disclosure of wireless telegraphy licence information on radio frequency and assignment use published by RA in
January 2002.
The format of the NATS response is to provide specific answers to the questions posed in the consultation paper and
to follow with supporting comments responding to other statements made in the consultation paper. NATS would
be willing to discuss in more detail the implications of the proposals and our comments as contained in this
document with the Agency if this would be of assistance.
Responses to s]2ecific questions in the consultation document.
Q.]
Do you think agree (subject to any safeguards on security and commercial sensitivity issues) that frequency
and assignment data should be open information? Give reasons for your answer.
NATS response 1.
NATS does not agree that frequency and assignment data for systems used for operational aviation
purposes should be open information in the ways being proposed in the consultation document. The reasons for this
opinion will be discussed more fully in answers to later questions but in essence the concerns are of the potential for
an increased threat to aviation security and the safety of air transport and the travelling public if frequency
assignment and site locations were to be put into the public domain in a single database. This opinion is equally
applicable to the information being made available to "industry" (interpreted to be the Radiocommunications
industry as a whole from the consultation document), as it is to it being made available to the general public.
It is also the case that certain systems used both directly and indirectly in the UK for operational aviation purposes
use assignments within bands that would not be immediately recognisable as having aeronautical related usage. We
would have concerns equal to those about the disclosure of details of assignments in "aeronautical" bands for
systems for which NATS holds standard licences in commercial bands, were sites and frequencies of these systems
to be identifiable as being used for aeronautical purposes (which would be the case if, for example the licensee
identity or, in some cases, the site location were to be disclosed). Examples of such systems would be fixed links
between radio sites or certain UHF PBR systems.
For specific discussion on the aeronautical bands within which the CAA makes UK frequency assignments to NATS
and other Air Traffic Service organisations, please see the NATS response to question eight.
1
Q.2
Do you think there should be industry information tools of assignments and frequencies should be made
available? What types of information would be a) beneficial to you/your organisation; b) lead to better use of the
spectrum; and c) enhance competition?
NATS response 2.
In terms of the internationally co-ordinated aeronautical bands (communications and navigation aids but not primary
surveillance), the level of information currently available within ICAO processes to national frequency planners,
NATS and other aviation users is sufficient for frequency planning within the aviation industry. NATS recognises
that the aviation industry has a duty to seek to use spectrum in the best ways however, experience has shown that
basic aeronautical assignment data can be misinterpreted when used with little or no knowledge of frequency
planning criteria, full system parameters or an appreciation of the safety requirements placed on aeronautical radio
systems. NATS would not view the enhancement of competition as being a valid issue within any aviation band.
NATS is therefore of the opinion that such information tools beyond those currently available within the aviation
industry are not necessary for the aviation bands.
Q.3
Would you support not disclosing names and contact information on the industry database, but allowing a
direct enquiry method on the lines outlined in paragraph 5.4? Give reasons for your answer.
NATS response 3.
The consultation paper refers to the Agency's wish to apply criteria and proposals given in section 5.4 of the paper to
the disclosure of aeronautical data. Almost all frequency bands used for terrestrial aeronautical systems are
exclusively allocated for aeronautical use. It would therefore be of little benefit to describe the use of a given site /
frequency as a "private business system", to use the example given in the consultation paper, because it would be
clearly identifiable as aeronautical from the frequency band. It is also likely that a site that is labelled as
"aeronautical" and is located near a given aerodrome or that lists assignments in an exclusive aeronautical band is
going to be related to the aerodrome. Equally, any site so identified but away from the immediate vicinity of an
aerodrome is likely to be operated by NATS. In NATS' opinion, any proposals for "hiding" the licensee of a given
site and frequency behind generic service descriptions and licensee codes would be of limited use in the aeronautical
context and is in fact comparable to full disclosure of use and user for aeronautical assignments.
In addition, the consultation document suggests (in section 5.4) that there could be an system via the Agency for
information within the "industry" database that would permit licensees to vet enquiries about their systems if
licensee identifying codes were used. The document makes reference to the Agency considering charging fees for
this or other access to databases: given the resource implications for either full or partial disclosure in terms of
licensees having to make facilities available to respond to enquiries, what provision would be made to cover
licensees'costs of responding to enquiries through RA ?
Q.4
If you do not support the direct enquiry method, would you support full disclosure of information on the
industry database, or is there another system that you would like to see employed?
2
NATS response 4.
NATS would not support full disclosure on an industry database for systems used for operational aeronautical
purposes, please see the response to question eight.
Q5
Do you agree that private network operators should be divided into two groups, with the associated
differing restrictions on what information is disclosed? Give reasons for your answer.
NATS response 5.
It is not clear whether or not air traffic service providers using bands not seen generally as
"aviation" would be considered as private network operators, i.e. whether sections 5 and 7.1 of the paper are
mutually exclusive. Were disclosure to go ahead of such aviation use, NATS would support such a split from the
safety and security aspects of UHF PBR at aerodromes and inter-site fixed links. However, this would depend on
how exactly these uses would be identified given that, for example, having a fixed link at a site where the site is
otherwise identifiable as being operated by an air traffic service provider would give a strong indication that the link
may be aviation related.
Q.6
Would you support (in the future) the Radiocommunications Agency offering a CD-ROM subscription
service for frequency and assignment data? If yes, what benefits do you envisage would be gained over the industry
database?
NATS response 6.
NATS believes that such a CD-ROM, if it were to cover "all" UK frequencies would require almost
constant updates to be of practical use, certainly if it were intended to facilitate self assignment in bands where this
would be appropriate and would therefore have substantial costs associated with it over an "industry" database.
While still not supporting the disclosure of any aviation frequency assignment details, in the general case a database
- with access safeguards where appropriate would appear to NATS to be a better option than a CD-ROM due to the
lower costs and complexity associated with maintaining a single, centralised data source.
Q.7
Do you agree there is a need for more disclosure of information about public networks? Give reasons for
your answer.
NATS response 7.
For broadcast services that are transmitted with the intention of being received by the public, there are clearly
requirements for site and frequency information to be available for the setting up of home equipment, aligning
antennas etc. Whether or not there is a requirement for more disclosure of such information for broadcast or public
communications networks is not a matter on which NATS can comment.
Q.8
Do you support further disclosure as outlined in paragraphs 7.1 & 7.2, for aeronautical and maritime, in
addition to disclosures already made for safety reasons? Give reasons for your answer.
3
NATS response 8.
It will be assumed in the response to this question that the assignments being referred to under section 7.1 of the
consultation paper are those in the exclusive civil aeronautical bands (which may also be shared with MoD for
similar purposes) and which are not subject to prepackaged WT Act licences, i.e. the frequencies used by ground
based infrastructure. Some of the comments below may also be valid for assignments used for operational
aeronautical purposes in other bands that have already been commented on in responses to earlier questions.
NATS does not support any disclosure of frequency and site information within the aeronautical bands in the types
of centralised database or CD-ROM formats being discussed in the consultation document. The main reasons for
not supporting the release of licensing data linking site locations and frequency assignments are the security and
safety implications of it being made possible to identify from a single data source the locations that provide the
communications or surveillance infrastructure for particular volumes of airspace or aerodromes. As noted elsewhere
in this response, NATS would view an "industry" database as being equivalent to a public access database in this
context.
We believe that it is worth re-iterating for the purposes of this consultation what information is and is not currently
made available for safety purposes.
*
VBF communications for en-route and aerodromes: the frequency only is published in official
documentation such as the UK AIP. No transmitter location information is made available or is required for
international co-ordination of the frequencies or for their use. For frequency planning purposes, either a nominal
centre point is provided for an aerodrome frequency or a volume of airspace is co-ordinated for an en-route
frequency. The general area of use of a communications frequency may appear on aviation maps, for example but
no information is published linking aeronautical VBF communications site locations and frequencies.
*
En-route navigation, navigation and landing aids at aerodromes: by definition the frequency and location
of these installations are both required and published for flight safety purposes.
*
Radar (surveillance): frequencies of primary radar systems are not made available, as there is no
requirement for interoperability with aircraft systems. Secondary radar operates on a pair of
internationally standardised fixed frequencies that appear in aviation standards documents. They are not
however, generally published for flight safety purposes. Radar installation locations may appear on
aerodrome charts if they are within the boundaries of the aerodrome. Locations of en-route radars are not
otherwise published.
Flight safety purposes aside, aeronautical and other radio stations may be marked on published maps (such as
Ordinance Survey) but their use, i.e. radar, navigation aid type, would not be identified.
The consultation document talks in terms of information already being made available for safety purposes to the
"aeronautical community" rather than "publicly"; NATS' view is that the current levels of disclosure of frequency
and site details as described above within the context of documents such as the UK Air Pilot (UK AIP) are
appropriate from the viewpoints of safety and security. While such official documentation is aimed primarily at the
aeronautical community it is publicly available. Proposals however to repeat and possibly augment this information
in centralised, officially published data sources (electronic or otherwise), such as those discussed in this consultation
are of significant concern.
Comments on the proposals and criteria contained in Section 5.4 of the consultation paper may be found in the
NATS response to question 3.
4
The benefits to aeronautical licensees of public or industa assignment databases.
Section 2.6.1 of the paper states that both an extension to the "Sitefinder" on-line database for public use and an
engineering database for industry use are being considered as Agency initiatives. Furthermore, the industry
database is expected to assist the functioning of a spectrum market. Spectrum trading and self-selection of
frequency assignments are cited in the consultation paper as being positive reasons for the disclosure of licensing
data. Assignments in the majority of bands used for aeronautical communications and navigation services are coordinated internationally
5
through ICAO processes (by CAA in the UK) and those for surveillance radar are co-ordinated through the UK's
inter-departmental IFPG process. In addition, there are other "qualifications" that operators must have obtained
under UK aviation legislation, e.g. the Air Navigation Order (ANO) prior to being able to apply for a frequency and
WT Act licence for an aeronautical system so neither spectrum trading nor self assignment are appropriate for
aviation bands. In addition, spectrum trading - and auctions - have also been recognised by the Cave Review 1 as
being inappropriate mechanisms for the assignment of aeronautical frequencies.
The resolution of interference issues has also been given as a positive reason for disclosure of assignment
information. In the aeronautical context, common examples of interference would be illegal "pirate radio"
broadcasts spilling over into VHF communications and navigation bands, illegal use of aeronautical (VHF comms)
equipment, local site issues (e.g. at an aerodrome) or attempts by flight crews to use communications frequencies
outside the Designated Operational Coverage (DOC) of the channel. RA deals with the first two of these through its
enforcement branch with assistance from other organisations as required so public or "industry" knowledge of
assignment data would not be of assistance in these cases. Interference due to site sharing issues, antenna
positioning etc. can be dealt with locally without requiring a central database of all assignments. In the final
example, detailed knowledge of DOCs and non-UK assignments (given the large reuse distances of aeronautical
frequencies) may be required to identify the interference source. NATS would consider that this information is in
the public domain through the ICAO European frequency planning processes and the CAA normally resolves such
cases, in consultation with RA where necessary. It would not be feasible, in NATS view, to hold or maintain such
detailed assignment information in the types of UK databases being proposed by the consultation paper (public or
otherwise) to assist interference resolution.
On the basis of the above arguments, NATS would suggest that an engineering database as described would be of
minimal benefit to the (aviation) industry. Furthermore, no indication is given in the consultation document as to
what individuals or organisations would be permitted to have access to the proposed "industry" database. Given the
security implications and concerns about the disclosure of aeronautical information that is discussed elsewhere in
the NATS response, we would see disclosure to "industry" as having the same negative security and safety
implications as would the disclosure of data to the public.
General comments on other issues raised in the consultation puer.
Section 2.5 of the paper discussing E-govemment makes reference to electronic site clearance processing,
e-licensing and interference complaints in the context of information to be released into the public domain as
background to this consultation. It is NATS understanding that site clearance is not a public domain process and is
restricted to Government Departments plus a number of other users (including NATS) under strict rules of
confidentiality. As such, it would not appear to be appropriate to bring this into a discussion of more public
disclosure of licensing data.
Equally, citing of e-licensing would not appear to be appropriate, as this is understood to be an electronic extension
of current licensing transactions. While this may have some ramifications under Data Protection legislation, perhaps
for the transfer of data between the Agency and its licensing contractors, it would not, in NATS understanding,
require further disclosure of licensing data to the public/industry.
1 Review of Spectrum Management by Professor Martin Cave for the Department of Trade and Industry and Her
Majesty's Treasury. March 2002