ASIA-PACIFIC TELECOMMUNITY
The 4th Meeting of the APT Conference Preparatory
Group for WRC-15 (APG15-4)
09 – 14 February 2015, Bangkok, Thailand
Document
APG15-4 /INP-38
09 February 2015
Islamic Republic of Iran
PRELIMINARY VIEWS ON WRC-15
AGENDA ITEMS 1.5, 1.15, 1.16, 1.17, 1.18
This document provides the preliminary views of the Islamic Republic of Iran on agenda items
1.5, 1.15, 1.16, 1.17 and 1.18 of WRC-15 for discussion at the fourth meeting of the APT
Preparatory Group for WRC-2015 (APG15-4), 09 - 14 February 2015 in Bangkok, Thailand.
It should be noted that all modification/additional proposed by this Administration are shown
with revision marks which are highlighted in Turquoise color.
These preliminary views are provisional and subject to any consideration until the final meeting
of the APT Conference Preparatory Group to be held before WRC-2015.
Agenda Item 1.5:
To consider the use of frequency bands allocated to the fixed-satellite service not subject to
Appendices 30, 30A and 30B for the control and non-payload communications of unmanned
aircraft systems (UAS) in non-segregated airspaces, in accordance with Resolution 153
(WRC-12);
1. Background
An unmanned aircraft system (UAS) consist of a geostationary satellite operated in the FSS, an
UA with an Earth stations on-board the UA to interconnect the communication link between an
UA and the associated Earth station, called "unmanned aircraft control station”(UACS). UA are
aircraft that do not carry a human pilot but that are piloted remotely, i.e. through a reliable
communication link from outside the aircraft. UAS operations up to now have been limited to
segregated airspace under RR 4.4. However, it is planned to expand UAS deployment outside of
segregated airspace.
There are a large variety of existing and envisioned applications of UAS in the fields of
economy, public safety and science. Further details on UAS applications in non-segregated
airspace can be found in Report ITU-R M.2171.The operation of UA outside segregated airspace
requires addressing the same issues as manned aircraft, namely safe and efficient integration into
the air traffic control system.
2. Iran Preliminary Views
I.R. of Iran supports the Method B (NOC) to the ITU’s RR.
Reasons for No Change:
 There are considerable technical, operational and regulatory obstacles for the use of FSS
for UAS CNPC links. Moreover, existing allocations for AMS(R)S as well as AMSS and
MSS, under certain conditions could satisfy the requirements for UAS CNPC in the
frequency bands of these services. It is worth to mention that at the recent interregional
information meeting held in Geneva in November 2014, several administrations and
Contact:
ALIREZA DARVISHI
CRA, MICT, I. R. IRAN
Email: darvishi@cra.ir
APG15-4/INP-38
satellite operators clearly mentioned the inappropriateness and non-feasibility of the use
of uncoordinated, incompletely coordinated commercial FSS which are not granted a
safety service for unmanned aircraft which is of very highly safety application.

Moreover no agreement was reached on the results of studies due to the fact that there is
a major divergence of views on the appropriateness, feasibility of the use of the FSS for
such a sensitive and delicate issue which is very high degree of importance in terms of
safety of flight and satiety of life.
In fact the study is at its very early stage and the activities of the ITU-R are in form of
‘Document toward Preliminary Draft New Report” which is far from being considered to yield
an acceptable/agreed (See I.R. of Iran’s contributions for previous WP 5B meetings: Document
5B/596-E and Document 5B/595-E). However, no change is also being considered by these
Administration acceptable /agreed results.
 This Administration in its contribution 5B/676 indicating that :
Quote
“This Administration maintains its position and is of the strong believes that:
a. The introductory text should remain as it is until all questions are answered and all
doubts are removed.
b. The document, irrespective of its development should NOT BE UPGRADED to a PDNR.
Until administrations which have raised concerns ,including this administration have the
opportunity to attend the meeting and discuss the matters further with an objective that
are divergence views are reconciled.
c. The document should continue to be placed in physical bold square bracket until the
subsequent meeting of WP 5B in 2015 in which this administration would have the
opportunity to attend that meeting and discuss the pending issues in detail with other
administrations.”
Unquote
Therefore, the title of the report of the document mentioned below should be as follows:
–
Document toward Preliminary draft new Report ITU-R RS.[UAS-FSS] – “Technical
and operational characteristics, interference and regulatory environments associated
with the use of frequency bands allocated to the fixed satellite service no subject to
Appendices 30, 30A, and 30B for the control and non-payload communications of
unmanned aircraft systems in non-segregated airspace”
 It is worth to mention that the referenced Resolution in Method A (Use of the fixed
satellite service) was never ever discussed in any WP 5B Meetings, at all. It was attached
to some input documents but due to the major disagreement about the subject matter the
Resolution is question was just attached without being discussed. Moreover, the content
of the Resolution is totally inappropriate and does not reflect the reality .
 As it is noted, there is a long list of disadvantage of Method A (More than 15 items)
which indicate a considerable degree of non feasibility and inappropriateness of the use
of commercial FSS :
a) 50% of which have not completed the coordination and even have only coordinated with
few among many affected administrations.
b) Within the rest of 50% for which blanket coordination has been announced, there is no
information on the level of interference that has been accepted.
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c) Moreover, even if and only if all coordination’s are completed ,there is no guarantee that
the future commercial FSS satellites currently in operation would not cause harmful
interference to the above- mentioned link.
d) Occurrence of interference for fraction of minute could create a catastrophic results as
tens of unmanned aircraft will be misguided which could collide with other unmanned and
or manned aircraft.
Agenda Item 1.15:
To consider spectrum demands for on-board communication stations in the maritime mobile
service in accordance with Resolution 358 (WRC-12);
1. Background
Resolution 358 (WRC-12) invites WRC-15 to consider, based on the results of ITU-R studies,
the need to possibly identify additional UHF channels within the bands already allocated to the
maritime mobile service for on-board communication stations; invites ITU-R to conduct, in time
for WRC-15, studies to determine the spectrum requirements and potential frequency bands for
on-board communication stations, taking into account the protection of services to which the
frequency band is currently allocated.
Some UHF frequencies, in frequency range 450-470 MHz, are currently identified in Radio
Regulation for on-board communication stations. Fixed and mobile services are allocated in
frequency range 450-470 MHz on a primary basis.
There are two footnotes in the Radio Regulations Article 5 related to the use of UHF on-board
communication frequencies: RR No. 5.287 and RR No. 5.288.
RR No. 5.287 says that in the maritime mobile service (MMS) six frequencies in UHF frequency
band may be used by on-board communication stations:
Quote
5.287 In the maritime mobile service, the frequencies 457.525, 457.550, 457.575, 467.525,
467.550 and 467.575 MHz may be used by on-board communication stations.
Where needed, equipment designed for 12.5 kHz channel spacing using also the additional
frequencies 457.5375, 457.5625, 467.5375 and 467.5625 MHz may be introduced for on-board
communications. The use of these frequencies in territorial waters may be subject to the national
regulations of the administration concerned. The characteristics of the equipment used shall
conform to those specified in Recommendation ITU-R M.1174-2. (WRC-07)
Unquote
It should be noted that some administrations use these frequencies for land mobile service
(LMS). In accordance with RR No. 5.286AA the frequency band 450-470 MHz is identified for
use by administrations wishing to implement IMT.
ITU-R Working Party 5B discussed methods at its 13th meeting in May 2014 concerning Agenda
item 1.15 and the number of methods has been reduced to one. This method is described in the
draft CPM text (Annex 3 to Document 5B/636) which supports analogue equipment using
25 kHz and 12.5 kHz channel spacing, digital equipment using on 12.5 kHz and 6.25 kHz
channel spacing. The method also proposes not to identify new frequencies for on-board
communications in UHF other than those indicated in RR. No. 5.287.
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2. Iran Preliminary Views
This Administration supports the following:
-
The identification of new frequencies for on-board communications in UHF is not
justified and therefore not necessary.
-
However the importance of on-board communications for ship safety operations is fully
recognized, together with the congestion in some geographical areas.
-
A more efficient usage of the existing frequencies could be achieved with the
systematic utilization of both 12.5 kHz and 6.25 kHz channel spacing for all the
channels identified in the RR for on-board communications. The numbering of these
channels should be clearly harmonized worldwide.
-
The implementation of digital technology will open the possibility for additional
operational features and a number of different standards are available.
-
For analogue technology the use of CTCSS and DCS could be used as a way to mitigate
the impression of congestion to the user.
-
For digital technology the use of DCS or an operational equivalent system could be
used as a way to mitigate the impression of congestion to the user. The LBT technology
should be used.
-
To achieve this, amendments to provision RR No. 5.287 and Recommendation ITU-R
M.1174 are necessary. Provision is made for 25 kHz, 12.5 kHz and 6.25 kHz channel
spacing.
-
To achieve a higher degree of flexibility for the use of systems, it is proposed to
indicate two frequency bands in RR No.5.287.
-
No constraints should be placed on the existing 25 kHz analogue on-board
communication systems with the least modification to existing equipment being
preferable.
The following modification is proposed for RR No. 5.287:
MOD
5.287 Use of the bands 457.5125n is proposed for t being preferableems, i the maritime mobile
service is limited to on-board communication stations.
The characteristics of the equipment and the channeling arrangement shall be in conformity with
Recommendation ITU-R M.1174-3. The use of these bands in territorial waters may also be
subject to the national regulations of the administration concerned (WRC-15)
Agenda Item 1.16:
To consider regulatory provisions and spectrum allocations to enable possible new Automatic
Identification System (AIS) technology applications and possible new applications to improve
maritime radiocommunication in accordance with Resolution 360 (WRC-12)
1. Background
Resolution 360 (WRC-12) resolves to invite WRC-15:
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1
to consider, based on the results of ITU-R studies, modifications to the Radio Regulations
(RR), including possible spectrum allocations, to enable new AIS terrestrial and satellite
applications, with ensuring that these applications will not degrade the current AIS
operations and other existing services;
2
to consider, based on the results of ITU-R studies, additional or new applications for
maritime radiocommunication within existing maritime mobile and mobile-satellite service
allocations, and if necessary to take appropriate regulatory measures.
1.1 Automatic Identification System
The AIS is a proven maritime data system, with a large number of ships equipped and a
supporting terrestrial and satellite infrastructure established. The AIS is designed to assist safety
of navigation.
AIS is used in the ship movement service for safety of navigation, it enables the identification of
stations using this system, provides information about a ship and its cargo. It provides a means
for ships to exchange ship data, including identification, position, course and speed, with other
nearby ships and coast stations.
The shipborne AIS, mandated under Chapter V of the International Convention for the Safety of
Life at Sea (SOLAS), has become well accepted by the maritime community and is also being
used by thousands of ships not subject to the SOLAS Convention. The AIS is supported by a
large number of shore based VHF infrastructures as well as being able to be detected by satellite,
though its effectiveness is unacceptably limited where VHF data link (VDL) loading is high.
The need for separate dedicated channels was recognized by WRC-12 and two additional
channels were designated. This new designation solves the problem for satellite detection.
AIS has the capability for data exchange by application-specific messages (ASM) for
complementary information. The AIS is routinely used by ships for navigation and crew
familiarity is a positive factor. AIS messages can be sent with a priority #1 (highest) through #4
(lowest). Critical link management messages including position report messages are the highest
priority (priority #1), safety related messages are the high service priority (priority #2) and some
of the other messages including ASM are the lowest priority (priority #4). The decision of
WRC-12 to assign new channels of the RR Appendix 18 to digital communication makes the
implementation and use of new digital communication means possible. The establishment of the
maritime AIS, the VHF data exchange and certain satellite communication components on these
new frequencies offers potential enhancements to VHF maritime safety communications on a
global basis to satisfy the increasing need for maritime radiocommunication for enhanced
maritime safety.
1.2 AIS VHF Data Link Loading
AIS VDL loading remains an issue to an increasing degree in many parts of the world due to the
proliferation of AIS applications, message types, services and equipment types plus the
unanticipated increase in user volume.
Noting that WRC-12 has provided four candidate channels from the Appendix 18 on an
experimental basis, to protect the integrity of the AIS VDL, it is considered beneficial to move
ASM to two of these channels.
The VDL is designed mainly for safety of navigation. The ships positions are continuously
transmitted on the VDL and the closer ships have the highest probability of reception. This
ensures that, even during high VDL loading, ships will receive all position reports from the
closest ships but fewer position reports from the more distant ships.
When the AIS VDL is used for data communications, it cannot in the same way tolerate loss of
AIS messages. Higher load on the VDL results in higher loss of AIS messages, which results in
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higher number of retransmissions. This will eventually result in the loss of target information on
the AIS VDL.
An increasing number of ASM will reduce the available time slots for the intended AIS
messages. With increasing demand for maritime VHF data communications, AIS will become
more heavily used which will lead to an overloading of the existing AIS1 and AIS2 channels.
So far, some administrations reported that the AIS VDL loading in high traffic area is nearing
critical limiting factor of 50% as noted in International Association of Marine Aids to
Navigation and Lighthouse Authorities (IALA) Recommendation A-124 Appendix 18 “VDL
Loading Management”. The new Report ITU-R M.2287 indicates the necessity of additional
channels for the new applications using AIS technology.
1.3 VHF Data Exchange concept
The main activity relating to resolves 1 and resolves 2 in Resolution 360 (WRC-12) relates to a
new concept called the VHF Data Exchange System (VDES) proposed by the IALA. Initially
proposed as a terrestrial system, with a possible satellite broadcast capability (space-to-Earth)
and called VHF Data Exchange (VDE), the current proposal includes transmit capability from
ships (and other stations) to satellites (Earth-to-space) on certain VHF Appendix 18 channels,
through VDES. The satellites could be in low Earth orbits and/or medium Earth orbits. It is
important to note that existing channels AIS 1 and AIS 2, and channels 75 and 76 as used for the
transmission of Message 27 (long-range AIS broadcast message) are all included in the VDES
plan, and that AIS itself, will play a crucial role, as will the Global Navigation Satellite System
(GNSS).
The VDES concept addresses functions of VDE, ASM and the AIS in the VHF maritime mobile
band.
The AIS 1 and AIS 2 (simplex channels) are intended to be preserved for their original purpose
of safety of navigation, position reporting and identification, in both the ship-to-ship and ship-toshore and shore-to-ship direction.
2. Iran Preliminary Views
This Administration, at this point of time, does not have any position on any of the methods
mentioned in CPM Report. However, this Administration is currently considering the no change
approach.
Agenda Item 1.17:
To consider possible spectrum requirements and regulatory actions, including appropriate
aeronautical allocations, to support wireless avionics intra-communications (WAIC), in
accordance with Resolution 423 (WRC-12)
1. Background
The aerospace industry is developing the future generation of commercial aircraft to provide
airlines and the flying public with more cost-efficient, safe, and reliable aircraft. One important
way of accomplishing these aims is to reduce aircraft weight while providing multiple and
redundant methods to transmit information on an aircraft. Wireless technologies can be
employed to accomplish these goals while also providing environmental benefits and cost
savings.
Current aircraft communications systems require complex electrical wiring and harness
fabrication, which adds weight to the aircraft and increased fuel costs. Wireless Avionics IntraCommunications (WAIC) is expected to improve flight-safety and operational efficiency, while
reducing manufacturing and operational costs. WAIC systems consist of radiocommunications
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between two or more transmitters and receivers on a single aircraft. Both the transmitter and
receiver will be integrated with or installed on the aircraft. In all cases, communication is part of
a closed, exclusive network required for aircraft operation. WAIC systems will not provide airto-ground or air-to-air communications or air-to-satellite communications, and will only be used
for safety-related applications.
Providing sensor information wirelessly is an example of an application of WAIC systems.
These sensors will be installed at various locations both within and outside the aircraft, and will
be used to monitor the health of the aircraft structure and its critical systems, and to
communicate this information within the aircraft to a central onboard entity which can make the
best use of such information. They include applications to monitor cabin pressure, fuel tank/line,
temperature, ice detection, landing gear, engine sensors, air data, etc. and applications to control
emergency lighting, cabin functions etc. WAIC systems are also intended to support data, voice
and safety related video surveillance applications such as taxiing cameras and may also include
communications systems used by the crew for safe operation of the aircraft.
As a result, WAIC technology will allow for better monitoring of the health or maintenance of
the aircraft, and it could also lead to improved aircraft manufacturing techniques. The combined
effects of these changes may provide the opportunity for lower costs of operations and
environmental benefits. The ability to use WAIC communication systems is important to the
civil aviation industry, but presents a significant challenge given the safety of life of existing and
planned aeronautical safety services.
In November 2010, ITU-R Study Group 5 approved Report ITU-R M.2197 - Technical
characteristics and operational objectives for wireless avionics intra-communications (WAIC).
The total radio frequency spectrum required for all types of WAIC application categories is
145 MHz. To reflect the diverging conditions and requirements, different categories of WAIC
systems are defined. These are based on the two criteria “data rate requirements” and “transmit
antenna location on the aircraft”, i.e. internal or external to the aircraft structure. For
determining bandwidth requirements, low rate and high rate systems are separately considered
due to differing technical requirements and technological restrictions their implementation may
face.
Given the fact that both the radio altimeter and WAIC systems are aeronautical applications and
are also regulated by aviation certification authorities as well as ICAO, additional efforts,
including development of standards and certification guidance material within the aviation
community could contribute in ensuring the safe operation of WAIC and radio altimeter
systems.
Further information on WAIC system technical and operational characteristics can be found in
the Report ITU-R M.2283.
Over the last two meetings of ITU-R WP 5B (November 2013 and May 2014), it has been
determined that the frequency bands 2 700-2 900 MHz and 5 350-5 460 MHz are not suitable for
the proposed WAIC systems in accordance with the requirements of this agenda item. On the
other hand, studies show that the band 4 200-4 400 MHz is compatible with existing services
and meet the requirements of the agenda item in accordance with Resolution 423 (WRC-12).
2. Iran Preliminary Views
This Administration prefers Method A as the follows, Due to the fact that any further
development on the matter could be brought to the attentions of future WRC under statutory
Agenda Item 4, proposing required modifications to reflect the latest status of development on
the matter:
Quote
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Adds a primary AM(R)S allocation to the frequency band 4 200–4 400 MHz. Relevant footnotes
are modified and new footnotes are added to limit the use to WAIC systems, maintain the status
of passive sensing in the EESS and SRS, and maintain the use of the ARNS. A new Resolution is
proposed in Method A. The method contains three different options for this new Resolution XXX
(WRC-15) in order to satisfy the agenda item.
Unquote
Agenda Item 1.18:
To consider a primary allocation to the radiolocation service for automotive applications in the
77.5-78.0 GHz frequency band in accordance with Resolution 654 (WRC-12)
1. Background
There has been significant growth in the use of automobile radar systems, and these systems are
expected to become relatively commonplace within a few years because of consumer demand
for increased vehicle safety. Studies have shown that the use of collision avoidance technology
can prevent or lessen the severity of a significant number of traffic accidents. In certain parts of
the world, automotive radars have successfully operated in this portion of the spectrum,
particularly the 76-77 GHz band, for many years without mitigation methods or deactivation
methods and without increased reports of interference to licensed services.
In accordance with Resolution 654 (WRC-12), a primary allocation to the radiolocation service
for automotive applications in the 77.5-78.0 GHz frequency band will be considered under
WRC-15 Agenda item 1.18. In this regard, ITU-R Working Parties (WP) 5A and WP 5B have
initiated technical, operational and regulatory studies as responsible groups for WRC-15 Agenda
item 1.18 with the help of other concerned groups.
After completion of studies in WP 5A, Recommendation ITU-R M.2057 “Systems
characteristics of automotive radars operating in the frequency band 76-81 GHz for intelligent
transport systems applications” was published in February 2014.
WP 5B has been developing new Report ITU-R M. [AUTOMOTIVE RADARS] titled “Systems
characteristics and compatibility of automotive radars operating in the frequency band 77.5-78
GHz for sharing studies” which will be completed in the next WP 5B meeting in November
2014.
Portions of the 76-81 GHz frequency band are allocated to the radio astronomy service, amateur
and amateur-satellite and radiolocation services on a primary or secondary basis and to the space
research (space-to-Earth) service on a secondary basis. At frequencies above 30 GHz, radio
propagation decreases more rapidly with distance than at lower frequencies and antennas that
can narrowly focus transmitted energy are practical and of modest size. While the limited range
of such transmissions might appear to be a major disadvantage for many applications, it does
allow the reuse of frequencies over very short distances and, thereby enables a higher
concentration of transmitters to be located in a geographical area than is possible at lower
frequencies.
2. Iran Preliminary Views
This Administration prefers Method A (Add a primary allocation to the RLS on a worldwide
basis, limited to automotive applications, between 77.5 GHz and 78 GHz) due to the fact that it
provides worldwide harmonization for safety and collision avoidance related automotive radar
applications in the frequency band 76-81 GHz, which, if implemented, will very likely result in
reduced traffic fatalities and injuries on the road. Moreover, the nature of these short range
automotive radars along with the propagation characteristics of the frequency band 76-81 GHz
will facilitate sharing with incumbent services.
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