Met Office Response to Independent Review of Radio Spectrum management Radio spectrum management review: a consultation paper. 1. Introduction Met Office is a Ministry of Defence Agency, with a core responsibility to provide operational forecast services for defence, civil aviation and public safety. Met Office use of radiofrequency spectrum is primarily for meteorological observing systems, i.e. Earth Exploration Service [passive], Meteorological Aids Service, Meteorological Satellite Service and Radiolocation Service [meteorological radars, wind profiler radars]. The Met Office uses these services to provide the basic measurements required to make meteorological forecasts. Most of the observations are exchanged in real time with similar observations from most countries world-wide. These observations also provide the basis for studies of global climate change. The observations are essential if the Met Office is to provide the core services required. The observations are also made available to commercial competitors providing forecast services. 2. Consideration of meteorological spectrum issues Meteorological radio services provide a continuous operational service that directly support safety of life services, defence services and public and commercial forecasting. However, in spectrum allocation meteorological use seems to be mainly grouped with radioastronomy, as a science service. Whilst some meteorological systems have a purely scientific basis, most meteorological services are used for real time operational work. In addition, meteorological spectrum use may often not be recognised in regulatory circles as spectrum use with implications for public safety. In recent years, the resources allocated by the Radiocommunications Agency to dealing with science services have been significantly reduced in favour of areas perceived to be associated with higher economic benefits. The Met Office would prefer a situation where realistic estimates of the economic and safety benefits of meteorological services were taken into account when assessing the priority to be given to the meteorological use of the spectrum. In this context, the Met Office has deployed a passive microwave radiometer system (AMSU-B) on American earth orbiting satellites to observe the distribution of water vapour around the world. This is a primary operational system for all meteorologists. Many of the critical observations from this system are made between 182 and 185 GHz. This band is reserved solely for use by the meteorological service in every country apart from the UK. In the UK, a national footnote allows fixed or mobile services to be introduced. There are no proposed commercial systems for use in this band, but the UK allocations for fixed and mobile have not yet been removed from the Radio Regulations. 3. Recent experience of spectrum allocation issues The Met Office has taken an active part in spectrum allocation studies since WRC-92 when the Mobile Satellite Service was allocated spectrum within the MetAids service bands before any sharing studies were conducted. Subsequently, it was shown that the proposed Mobile Satellite systems are totally incompatible with MetAids service use. Most of the meteorological radio systems in use are specialised aspects of spectrum use , and so the Ministry of Defence agreed that the Met Office could be directly represented in spectrum allocation study groups. The earth exploration satellite [passive] service requires protected frequency allocations aligned internationally around the world associated with specific atmospheric absorption bands. The Metaids service and meteorological satellite services also require radiofrequency allocations that are aligned around the globe, in order to minimise the manufacturing and development costs of ground equipment and consumables. In the case of the Metaids service, the balloon borne equipment may drift across international boundaries and international co-ordination by the meteorological service is essential. It is vital to the Met Office that these globally aligned allocations are retained and that future spectrum allocation policy recognises the global nature of meteorological operations. As the main MetAids service bands are aligned around the world, these have been targeted for commercial development by mobile satellite services. The current regulatory mechanisms have allowed meteorologists to justify their use of this spectrum, and to demonstrate that improved radio design is freeing up spectrum for developments in the Meteorological satellite service that also shares much of the same bands. Whilst the methods used to study spectrum allocation issues can be extremely manpower intensive, the Met Office prefers to participate in these structured types of studies that produce an effective and reliable evaluation of the feasibility of sharing. 4. Improved efficiency of spectrum occupation The Met Office pays for spectrum use for the MetAids service, under the arrangements for administrative pricing introduced for defence services. The introduction of these charges has proved beneficial in ensuring that he Met Office only registers spectrum use that is essential. Spectrum occupation will also be reduced in time as the commercial manufacturers develop the necessary technology. The Met Office accepts the implementation of pricing incentives to reduce spectrum occupation. However, the pricing must be balanced by a realistic view of the time taken to develop the spectrum efficient technology. The level of pricing must also take into account the consequent effect of increased Met Office charges to other government customers. For instance, there are concerns about the proposed application of administrative charges to the UK weather radar network, operated jointly with the Environment Agency. 5. Conclusion In recent years the Met Office has found it necessary to engage actively in spectrum allocation issues. It has received much useful help from the Radiocommunication Agency. There have been occasional difficulties, as noted above, in dealing with certain commercial interests. It is clearly a problem to balance between developing commercial proposals for the future ( some of which will not materialise) against damaging some of the primary meteorological observing systems in service. Up till now, a satisfactory outcome has emerged from the regulatory negotiations, and commercial progress in other services has not been blocked by meteorological requirements. The Met Office would be happy to discuss these issues further with Professor Cave at his convenience.