only on a secondary basis. The secondary nature of this allocation currently is not qualified in any manner, and does not include any references to the operation of GMDSS systems, their priority vis-à-vis other services or spectrum uses, or the application of No. 4.10 of the ITU RRs to any safety services or systems operated under this secondary allocation. The Changes Proposed under View B Avoid Potentially Harmful Impacts on Adjacent Spectrum Users under View A There are essentially five areas of disagreement between View A and View B: Frequency Range for GMDSS View A would amend the ITU RRs to permit GMDSS operations in the entire 1 616-1626.5 MHz band (through the addition of a new No. 5.GMDSS to the ITU RRs). In contrast, View B would amend the ITU RRs to permit GMDSS operations in the 1 618.725-1 626.5 MHz band—the actual band segment that has been proposed for use by a new GMDSS satellite system (which is consistent with the existing AMS(R)S authorization granted by the Commission to Iridium). Application of No. 4.10 View A would apply the provisions of No. 4.10 to GMDSS operations without qualification (through revisions to No. 5.368 of the ITU RRs). The absence of clarifying language, together with other changes proposed under this view, suggests that GMDSS would be entitled to certain protections vis-a-vis adjacent spectrum uses (including existing services). Particularly in the absence of any studies establishing the compatibility of GMDSS in the band with other spectrum uses, this suggestion is inconsistent with the mandate set forth in AI 1.8 and Res. 359, as discussed above. In contrast, View B would make clear, through additional language in No. 5.368, that No. 4.10 would apply to the GMDSS only on an intra-system basis—i.e., solely with respect to the prioritization of different spectrum uses by that GMDSS satellite system within that spectrum range (as opposed to on an inter-system basis). This is consistent with the proposed changes to Article 15 under View A. Modifications to Article 15 of the ITU RRs View A would modify Table 15-2 to provide that GMDSS communications have certain priority without specifying the services or spectrum uses with respect to which such priority would exist.
only on a secondary basis. The secondary nature of this allocation currently is not qualified in any manner, and does not include any references to the operation of GMDSS systems, their priority vis-à-vis other services or spectrum uses, or the application of No. 4.10 of the ITU RRs to any safety services or systems operated under this secondary allocation. The Changes Proposed under View B Avoid Potentially Harmful Impacts on Adjacent Spectrum Users under View A There are essentially five areas of disagreement between View A and View B: Frequency Range for GMDSS View A would amend the ITU RRs to permit GMDSS operations in the entire 1 616-1626.5 MHz band (through the addition of a new No. 5.GMDSS to the ITU RRs). In contrast, View B would amend the ITU RRs to permit GMDSS operations in the 1 618.725-1 626.5 MHz band—the actual band segment that has been proposed for use by a new GMDSS satellite system (which is consistent with the existing AMS(R)S authorization granted by the Commission to Iridium). Application of No. 4.10 View A would apply the provisions of No. 4.10 to GMDSS operations without qualification (through revisions to No. 5.368 of the ITU RRs). The absence of clarifying language, together with other changes proposed under this view, suggests that GMDSS would be entitled to certain protections vis-a-vis adjacent spectrum uses (including existing services). Particularly in the absence of any studies establishing the compatibility of GMDSS in the band with other spectrum uses, this suggestion is inconsistent with the mandate set forth in AI 1.8 and Res. 359, as discussed above. In contrast, View B would make clear, through additional language in No. 5.368, that No. 4.10 would apply to the GMDSS only on an intra-system basis—i.e., solely with respect to the prioritization of different spectrum uses by that GMDSS satellite system within that spectrum range (as opposed to on an inter-system basis). This is consistent with the proposed changes to Article 15 under View A. Modifications to Article 15 of the ITU RRs View A would modify Table 15-2 to provide that GMDSS communications have certain priority without specifying the services or spectrum uses with respect to which such priority would exist.