Comments by AWCIA to the FCC04-Jul-2010
TO: The Federal Communications Commission
SUBJECT: Comments regarding:
DA 10-1035 Released: June 4, 2010
OFFICE OF ENGINEERING AND TECHNOLOGY REQUESTS INFORMATION ON USE
OF 1675 – 1710 MHz BAND
ET Docket No. 10-123
The American Weather and Climate Industry Association (AWCIA) respectfully submits that the spectrum in question is currently utilized for critical purposes that have significant value to the United States in saving lives, protecting property and growing the American economy.
By way of background, the AWCIA is the trade association for the professionals who make weather their business. Our organization represents a diverse weather industry and the industry's diverse needs. We are an organization run by its members, for its members. We are committed to growing the industry by providing services to our members, ultimately making a stronger American Weather Enterprise.
Our members are businesses that have a significant impact on how weather information is collected, disseminated and enhanced to provide custom services to weather-sensitive businesses as well as the general public. CWSA members build weather sensors, implement government weather programs, broadcast weather presentations, disseminate raw government and privately-owned weather data, generate weather products and services, and provide specialized services to a wide variety of markets. We are the "value-added provider" or extension to the Government supplied weather data because we assimilate and tailor the information for specific uses. Our member corporations employ from 2 - 1000+ employees and cover a wide spectrum of capabilities and sizes.
The imagery and data received from various government-supplied satellite space station downlink transmissions that utilize the 1675-1710 MHz band is used by a number of AWCIA members:
o As a tool in the creation of the forecasts and warnings that AWCIA companies make available to their media and commercial clients and to the general public;
o To create imagery and other products that are supplied by AWCIA member companies to their clients and partners in media for use in their public broadcasts and other public-reaching activities;
o To create imagery and other products that are supplied by AWCIA member companies to their clients and partners in business and government as a tool in their decisions that impact life, safety and commerce; and
o To create imagery and other products that are supplied by AWCIA member companies to the general public through their web sites, mobile web sites, television networks, and other public reaching media.
In its Public Notice, the FCC states that “It may be possible that reception of the weather satellite downlink transmissions could occur at a relatively small number of sites and be distributed via terrestrial services, such as over the Internet or other managed services.”
We do not believe that this proposed solution is viable, for several reasons.
The entire set of all the raw satellite data (including rapid scan and super rapid scan additional data during critical weather situations) is available in the current downlink transmission, so that AWCIA member companies and other users of this data can utilize the complete data set in the generation of a variety of satellite images and data products, in algorithms that generate a variety of current and forecast products, and as a tool in the production of forecasts and warnings.
There is concern that if the current satellite-based dissemination was replaced with a terrestrial dissemination method such as the internet, then the complete dataset (all raw imager and sounder data) would no longer be available and, if it were, that it would not be available in a timely manner.
Although a subset of the raw satellite data is currently available through the internet, there is a significant lag time between the satellite delivery and the internet availability, generally on the order of five to ten minutes.
AWCIA member companies and others utilize the satellite data as a component of their warning decisions, which save lives and property – particularly in areas where there is no radar coverage. While for many items, a delay of this magnitude might be trivial, given the nature of rapidly changing weather situations and importance of this data in saving lives and protecting property, the timeliness of this data is critical.
The satellite data is a very large data set and, thus far, internet dissemination of large meteorological data sets has been problematic in both timeliness and reliability. By way of example, there have been numerous issues with the internet transmission of level II Doppler radar data. The existing dissemination system for satellite data has proved to be extremely reliable.
The current satellite based dissemination method requires only that the hardware, systems and software already in place remain so, and the only additional requirement is a backup generator in the case of power failure. With internet-based dissemination, there are more potential failure points, including the routers and telecommunications circuits through the entire pipeline. Therefore, the current satellite based method is much more reliable during times of commercial power interruptions etc – such as those that occur in the aftermath of a natural disaster.
The data volume from the GOES satellites will increase substantially after the GOES-R deployments (scheduled for 2015 and 2016). This would further complicate the ability to disseminate the data in question via the internet.
In addition, AWCIA member companies and others have made significant financial investments in the infrastructure needed from both the hardware and software sides to receive the data in the raw formats as quickly as possible. A change to internet or other delivery would require new investments to replace these existing architectures.
It has been estimated that weather directly impacts about one quarter of the U.S. economy. It directly affects both safety and quality of life. The satellite data is a critical component of the American Weather Industry and its ability to provide forecasts and warnings that save lives, protect property, improve quality of life, and grow the economy.
We strongly believe that if the current availability of the weather satellite downlink transmissions were to end, there would be significant adverse effects on safety and economic activity in the United States.
If you have any questions please feel free to contact me directly.
Very truly yours,
Steven A. Root
Certified Consulting Meteorologist
American Meteorological Society #321
American Weather and Climate Industry Association (AWCIA)
President / CEO
1015 Waterwood Parkway, Suite J
Edmond, OK 73034