The Committee on Radio Astronomy Frequencies (CRAF) is a committee of the European Science Foundation (ESF).
The European Science Foundation (ESF) is an association of its 62
member research councils and academies in 21 countries. The ESF brings European
scientists together to work on topics of common concern, to co-ordinate the use
of expensive facilities, and to discover and define new endeavors that will
benefit from a co-operative approach
On behalf of European radio astronomers, the ESF
Committee on Radio Astronomy Frequencies, CRAF, coordinates activities to keep the
frequency bands used by radio astronomers free from interference.
The scientific work sponsored by ESF includes basic research in the natural
sciences, the medical and biosciences, the humanities and the social sciences.
The ESF links scholarship and research supported by its members and adds
value by cooperation across national frontiers. Through its function as
coordinator, and also by holding workshops and conferences and by enabling
researchers to visit and study in laboratories throughout Europe, the ESF works
for the advancement of European science.
The Committee on Radio Astronomy Frequencies of the European Science Foundation, CRAF, coordinates activities to keep the frequency bands used by radio astronomers free from interference. CRAF represents the radio astronomy communities in 17 European countries. The European Incoherent Scatter Facility, EISCAT, the European Space Agency, ESA, and the Institute for mm-Wave Radio Astronomy, IRAM, are also members of CRAF.
In Europe, scientific research is generally funded by public money. Furthermore, scientific facilities may extend over Europe as a whole and even beyond this region (such as in Very Long Baseline Interferometry). Therefore, CRAF appreciates that the Green Paper pays attention to the science services; one of which is the radio astronomy service.
CRAF welcomes the Green Paper of the European Commission as a discussion document and recognizes the relevance of a debate on the current European spectrum policy. However, CRAF observes that in the Green Paper an analysis of strong versus weak aspects of the current practice is lacking. CRAF regrets this. In Resolution 92/C318/01 of November 19th, 1992, the Council of Europe invited the Commission "to give full consideration in future to the mechanism of ERC decisions as the primary method of ensuring the provisions of the necessary frequencies for Europe-wide radio services". The mentioned analysis could have contributed to this aim.
CRAF considers that the working method and results of CEPT-ERC in general satisfactory. In a satisfactory manner, measures have been taken towards an open, transparent decision making process. This process is also open for contributions from interested parties. Nevertheless, CRAF appreciates proposals to improve mutual co-existence in the radio frequency domain of the various radiocommunication services.
2.1. Active and passive services
CRAF observes that the spectrum policy presented in the Green Paper is discussed primarily in terms of interests and requirements for the active radiocommunication services. A strategic view on the specific interests and requirements of the passive (i.e. receive-only) services and applications compared with those of the active services is, however, lacking. CRAF regrets this, because it reduces the balance of the spectrum policy, since the requirements and characteristics of active and passive services are significantly different.
2.2. Spectrum impurity - cooperation between active and passive users of radio needed
The Green Paper is clear in its statements on spectrum availability for each of the radiocommunication services, i.e. on telecommunications, broadcasting, transport and also on R&D. However, availability in a regulatory sense is different from availability at a quality level which is sufficient for the radiocommunication's requirements. Spectrum impurity degrades spectrum efficiency and reduces spectrum availability dramatically, especially when inadequate spread-spectrum modulation techniques are used. Technological cooperation between the users in these different radiocommunication services may well lead to a significant alleviation of the problem. The results of such a cooperation can be considered as beneficial for all users of the radio spectrum. The cooperation between active and passive users of the radio spectrum needs special attention because of the different requirements for the active and passive services.
For the benefit of the active and passive services, industry, operators and users of the provided facilities, cooperation between active and passive services could be improved and the European Commission could play an important and stimulating role in this respect.
CRAF considers, therefore, that the need for such a cooperation could be more clearly articulated as a strategic goal in the Green Paper.
2.3. Space systems - defective space system
CRAF observes that the spectrum policy outlined in the Green Paper is primarily written from the perspective of terrestrial use of radio. Coordination and regulatory procedures for terrestrial radiocommunication applications exist already to a great extent. This holds also for defective systems which have harmful impact on other radiocommunication services.
A great concern of CRAF is the existence of defective space systems of which at the present day about half a dozen can already be identified. In many respects the ITU-R Radio Regulations are not adequate to give guidance to the Administrations to manage such situations. These systems defects may originate from (1) malfunction of a system, from (2) ignorance in the design and construction phase of the system, or from (3) plain bad system design. These defects are known because they generate harmful interference or produce some other negative impact on other systems. But nonetheless, at present operators of such systems meet no constraints.
CRAF considers that a strategic position of the European Commission on this issue is urgent and needs to be developed in close cooperation with the CEPT. Such a strategy would be of great help to Administrations, especially when it is notified that there are reasons to expect that the extent and impact of this problem on other applications of radio (space based or terrestrial) is rapidly increasing.
A strategy on defective space systems has as a complicating aspect that some operators of space applications do not pay adequate attention to system quality if in their view this is not commercially justified.
3. Specific Comment
The Green Paper formulates Issue 4 as:
ISSUE 4
The European Commission would welcome views on the link between Community policy on radio
equipment, standards, and radio spectrum, with particular regard to the co-operation between
bodies responsible for standards and radio spectrum and the measures needed at the operational
level of radio spectrum management.
And asks:
4 (a) Is there a need to improve the link between the elaboration of standards and the harmonisation of radio spectrum allocation for pan-European services in the areas of telecommunications, broadcasting, transport, and R&D?
In reaction to this question, CRAF observes that it is not yet common practice, that in the process of the development of standards spectrum issues are adequately taken into account. The industrial view on standards appears to be directed to issues of interconnectivity rather than those of spectrum purity and efficiency. CRAF considers that in standards development the issue of spectrum pollution should be addressed adequately. It is also important that in the development of standards, active users of the radio spectrum take the requirements of passive radiocommunication services into account.
CRAF, therefore, recommends that especially in this process of standards development, the cooperation between active and passive users of the radio spectrum should become more manifest to avoid complicated corrective work at a later phase. The European Commission could play a stimulating role to achieve this.