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4 Spectrum Management INTRODUCTION and management manual.2 The NASA spectrum manage- ment organization is shown in Figure 4.1. NASA has extensive communications and remote sens- The associate administrator for the Space Operations ing systems, and the availability of adequately protected Mission Directorate (AA/SOMD) is designated the NASA electromagnetic (EM) spectrum enables the implementation spectrum manager and is responsible for ensuring compli- of these systems. NASA headquarters and various field cen- ance with pertinent international and national rules and regu- ters play key roles by ensuring that NASA has access to EM lations affecting all NASA radio frequency spectrum users. spectrum and that it complies with U.S. and international The AA/SOMD has delegated authority for the overall plan- regulations regarding spectrum use. ning, policy, and administration of the NASA Spectrum There are approximately 150 spacecraft in NASA’s pur- Management program to the director, Spectrum Policy and view that rely on access to various passive and active spec- Planning (HQ/SOMD), who is also the NASA representa- tral bands to conduct space research, space operations, pas- tive to the Interdepartment Radio Advisory Committee sive and active Earth exploration, meteorological (IRAC), which assists the National Telecommunications and monitoring, intersatellite communications, radionavigation, Information Administration (NTIA) in the allocation, man- and deep-space research. Achieving NASA’s mission and agement, and use of spectrum by the U.S. government. Other vision relating to space exploration, scientific discovery, and personnel include the deputy director, Spectrum Policy; na- aeronautics research implicitly requires the involvement of tional and international spectrum program executives; cen- the spectrum management element in the planning and ter spectrum managers; and various staff members.3 implementation of these programs. The director, Spectrum Policy and Planning (HQ/ NASA’s spectrum policy and planning organization at SOMD), establishes policies and procedures, and the na- NASA headquarters and supporting centers represents and tional and international program executives implement them. advocates for NASA’s needs for electromagnetic spectrum The international program executive directs activities related in national and international spectrum regulatory forums, to the electromagnetic spectrum that involve entities exter- obtains operational authority for NASA programs, supports nal to the United States, including the International Tele- the federal government’s four-stage review process, obtains communication Union (ITU), other non-NASA civilian domestic assignments and international registration, ad- space agencies (e.g., European Space Agency, Japan Aero- vances U.S. requirements globally, formulates spectrum space Exploration Agency, and others), and the Space Fre- policies in national and international regulatory bodies, pro- quency Coordination Group (SFCG). The national program vides technical advocacy in support of U.S. commercial aero- executive directs domestic EM spectrum activities involving space industries, facilitates private-sector use of spectrum, entities internal to the United States, including the NTIA and and encourages commercialization of space. the Federal Communications Commission (FCC). The na- tional program executive also ensures that the spectrum op- Spectrum Management Organization erational plan, 5-year plan, and long-range plan are updated and cooperates in assisting the NTIA in its federal spectrum The spectrum management program element and criti- strategic planning effort. cal personnel are defined in that element’s policy directive1 31
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32 REVIEW OF THE SPACE COMMUNICATIONS PROGRAM NASA Spectrum Manager SOMD AA Space Operations Assistant AA Space Operations Director, Spectrum Policy National Program International Program Support Contract Center Spectrum Support Contract ITT Industries Managers ASRCMS Headquarters Spectrum Management Forum FIGURE 4.1 NASA spectrum management organization. SOURCE: David Struba, NASA, “NASA Spectrum Management,” briefing to the NRC Committee to Review NASA’s Space Communications Program, Washington, D.C., January 26-27, 2006, p. 8. Headquarters Spectrum Management Forum Space Communications Complex (DSCC), and various test facilities. The NSMG meets annually under the leadership The Headquarters Spectrum Management Forum of the national spectrum program executive at NASA head- (HSMF) was established to ensure NASA’s compliance with quarters. Office of Management and Budget Circular A-11, Section 33.4, which provides that agencies should consider the eco- Field Centers nomic value of radio spectrum used in major telecommuni- cation, broadcast, radar, and similar systems when develop- The Glenn Research Center (GRC) spectrum manage- ing economic and budget justifications for procurement of ment organization, which reports to NASA headquarters but these systems. In addition, the HSMF identifies and vali- is located at GRC, is responsible for working all spectrum dates future spectrum requirements and ensures intra-NASA issues with the center spectrum managers on a shared, but compatibility by coordinating spectrum requirements among complementary, basis with the national and international the various mission directorates. Members of the HSMF in- regulators. clude liaisons from the Space Operations Mission Director- Each field center, JPL, the Goldstone DSCC, and the ate, Exploration Systems Mission Directorate, Science Mis- various test facilities has a spectrum manager to ensure that sion Directorate, and Aeronautics Research Mission all electromagnetic emissions comply with U.S. regulations Directorate, and the external relations spectrum liaison, the and to ensure the electromagnetic integrity of their facility. legislative affairs spectrum liaison, and the general counsel The center spectrum managers provide national, interna- spectrum liaison. The director, Spectrum Policy and Plan- tional, on-center, and miscellaneous support. They are in- ning (HQ), chairs the HSMF with support from the national volved in the pre-acquisition and acquisition processes and and international spectrum program executives. The HSMF provide briefings on spectrum management to new projects. meets at least once every 90 days. The Goddard Space Flight Center (GSFC) is respon- sible for the spectrum management of the Ground Network NASA Spectrum Management Group and the Space Network, and JPL is responsible for spectrum management of the Deep Space Network. Spectrum man- The NASA Spectrum Management Group (NSMG) agement for a mission is a shared and complementary re- provides a forum for the exchange of information on spec- sponsibility: GSFC or JPL is responsible for network spec- trum management requirements, actions, and issues. The trum management, and the program center is responsible for NSMG is composed of spectrum managers from each cen- spacecraft spectrum management. ter, the Jet Propulsion Laboratory (JPL), the Goldstone Deep
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33 SPECTRUM MANAGEMENT Budget The spectrum management program element is regularly involved in national and international meetings to advance The annual budget for the spectrum management pro- its long-term spectrum management goals. NASA’s success gram element is approximately $6 million per year and in- can be indirectly assessed in terms of the adoption of its cludes 17 full-time-equivalent civil service employees and positions through the frequent national WRC preparatory 24 work-year-equivalent contractors.4 meetings, periodic international WRCs, annual SFCG meet- ings, and periodic Inter-American Telecommunication Com- ASSESSMENT mission (CITEL) meetings. Formulation of the Program Plan Connection to the Broader Community While NASA’s strategic plan5 does not specifically ad- NASA is a member of the NTIA Interdepartment Radio dress spectrum management, all of NASA’s space commu- Advisory Committee, the International Telecommunication nications programs rely on the availability of spectrum and Union Radiocommunication Sector (ITU-R), SFCG, and NASA’s ability to meet the complex national and interna- CITEL, and it coordinates spectrum utilization with other tional regulatory requirements. government agencies, the commercial space industry, and NASA’s Headquarters Spectrum Management Forum, international space-faring nations. NASA interfaces with chaired by the director, Spectrum Policy and Planning, iden- multiple internal, national, and international venues in the tifies and validates future spectrum requirements and coor- area of spectrum management (Figure 4.2).7 NASA chairs dinates spectrum management across all of NASA’s space ITU-R U.S. Study Group 7 (Science Services) and two U.S. communications programs. working parties on space science, and it contributes to vari- The spectrum management program element has mul- ous other ITU-R U.S. study groups and working parties. tiple short- and long-term goals and objectives:6 (1) obtain Domestically, the national spectrum program executive adequate spectrum to support NASA programs, (2) ensure is the NASA representative to the Spectrum Planning Sub- compliance with national and international rules and regula- committee, Frequency Assignment Subcommittee, and tions, (3) ensure timely processing of spectrum allocations Technical Subcommittee of the Interdepartment Radio Ad- and frequency assignment requests and dissemination of visory Committee of the NTIA. These subcommittees inde- regulatory changes, (4) provide guidance to NASA mission pendently review NASA’s requests for frequency authoriza- program managers, (5) identify and mitigate radio frequency tion and may request additional analysis to support requests interference, either from or to NASA programs, (6) plan and for frequency authorization. obtain new allocations or enhanced radio regulations through Internationally, the FCC International Telecommunica- national and international organizations, (7) provide spec- tion Advisory Committee (ITAC) General Guidance Docu- trum planning and support for NASA’s technology transfer ment8 governs U.S. participation in the ITU-R and in the mission, and (8) advocate rules and rule changes that sup- CITEL PCC II (radio communication, including broadcast- port the lowest-life-cycle-cost technical solutions to NASA ing) organizations. In particular, prior to submission of any programs for meeting their communications needs. These U.S. document to an international meeting of the ITU-R, or goals and objectives require an ongoing and long-term com- to the Radio Regulations Board, or to meetings of CITEL mitment of funding. PCC II, the document must be reviewed and approved by the The spectrum management program element is differ- U.S. Department of State in consultation with the FCC and ent from typical NASA development programs in that there NTIA. The U.S. ITAC-R review process ensures that U.S. is no hardware development, and the program requires a government inputs are technically sound and comply with long-term and ongoing commitment. NASA has made a sig- national policy. nificant commitment to spectrum management in both the NASA is one of the foremost leaders in spectrum man- national and international communities, and the committee agement and is certainly on a par with the European Space expects that this commitment of agency resources will con- Agency (ESA), Centre National d’Etudes Spatiales, Japa- tinue in the future. In addition, progress is dependent on the nese Aerospace Exploration Agency, the Australian Com- processes of external domestic and international agencies monwealth Scientific and Industrial Research Organisation, such as the NTIA and ITU. Although compliance with exist- and the Indian Space Research Organisation. NASA gener- ing regulatory policies and procedures is generally straight- ally operates in the space research and deep-space bands, forward, the allocation of new bands and services requires which are different from the bands used by military and com- years of effort, given that World Radio Conferences (WRCs) mercial space systems. In 2000, a NASA report evaluated meet infrequently. NASA has a long-term relationship with whether commercial space systems could replace the Track- other space-faring nations and international organizations ing and Data Relay Satellite System (TDRSS), and the re- and has been successful in advocating its spectrum manage- port concluded that commercial systems cannot provide ment goals. The committee expects these relationships to wide-range, continuous coverage of low-Earth-orbit satel- continue in the future.
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34 REVIEW OF THE SPACE COMMUNICATIONS PROGRAM Domestic Venues STATE FCC Radio Sector Advisory National Committee/ Committee NTIA IRAC Special Industry RCS/ Groups SPS/ OTHER SSS/ AGENCIES FAS/ NASA TSC/ DOD/ Ad Hoc NSF/ SOMD Committees NRO GRC FIELD NOAA CENTERS HQ Spectrum Spectrum Managers ITU SOMD Management Group SFCG Spectrum Forum ISS R-Sector CITEL Coordination PCC-II CCSDS Formal International BILATERALS ESA Venues Frequency JAXA Coordination Informal Group Frequency Coordination International Group Venues FIGURE 4.2 NASA spectrum management program element involvement with national and international groups. SOURCE: David Struba, NASA, “NASA Spectrum Management,” briefing to the NRC Committee to Review NASA’s Space Communications Program, Washington, D.C., January 26-27, 2006, p. 10. lites and support NASA’s real-time communications require- • A proposed telecommunication relay network for ments.9 NASA’s Space Network is, however, interoperable Mars exploration and guidelines for the assignment of radio with satellites from other space agencies. NASA is a mem- frequency spectrum for communications in the Mars region. ber of the SFGC, which provides a forum for multilateral discussion and coordination of spectrum matters concerning NASA is also coordinating its utilization of the radio space research, space operations, and so on. frequency spectrum in the lunar region with the international In anticipation of future missions, NASA has submitted community of space-faring nations at technical and inter- to the ITU-R and SFCG several documents that address spec- governmental meetings. trum standards for missions to the Moon and Mars. These include: Methodology • The definition of frequency bands for human and NASA has extensive policies, procedures, and processes robotic exploration of the Moon compatible with deep-space regarding spectrum management in order to provide the missions as well as other guidance for spectrum manage- overall radio frequency spectrum implementation and ad- ment in the lunar region, and ministration policies necessary to support present and future programs. These include:
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35 SPECTRUM MANAGEMENT • NASA Electromagnetic (EM) Spectrum Manage- • Deep Space Network S-band uplinks. NASA oper- ment Policy Directive, NPD 2570.5D;10 ates Deep Space Network uplinks from Madrid (Robledo), • NASA Radio Frequency (RF) Spectrum Manage- Spain; Goldstone, California; and Canberra (Tidbinbilla), ment Manual, NPD 2570.1;11 Australia, in the 2110-2120 MHz band, and this band over- • NASA Long Range Electromagnetic Spectrum laps the IMT-2000/UMTS band; however, few existing Forecast;12 NASA deep-space missions currently operate in this band, • NASA EM Spectrum Operational Plan;13 and and no future missions will operate in it.21 In Canberra, this band is not allocated for IMT-2000 spectrum licensing,22,23 • Implementation plans unique to each NASA and, in a 2001 report,24 the Australian Communications center. Authority concluded that 3G mobile services would be able The committee met with the Goddard spectrum man- to successfully operate in the Canberra area without any sig- nificant short-term interference. In Goldstone, the FCC25 ager to assess the spectrum management program at a repre- sentative field center. Goddard was selected because the recognized that NASA will continue to operate in this band, TDRSS constellation and many Earth science programs are and it directed that advanced wireless services licensees must managed there. The committee’s assessment is that the accept any interference received from the Goldstone Deep Goddard spectrum management program is well managed, Space Network facility. In Madrid, the use of this band is and there is a clear and unambiguous understanding of roles constrained because of certain actions taken by Spain in sup- and responsibilities and of how the center spectrum manage- port of its national auctions; however, NASA will be able to ment program fits into the overall NASA spectrum manage- access and use the band based on ongoing negotiations and ment program. The Goddard spectrum manager is an inte- agreements with the Spanish Ministry of Telecommunica- gral part of the pre-acquisition and acquisition process for tions. new missions; he briefs every new mission on national and international spectrum management requirements. The Finding: NASA has been very effective in protecting its ac- Goddard spectrum manager has 4.5 support personnel, and cess to the radio frequency spectrum needed for space com- these personnel are used effectively and efficiently. They munications. In addition, the potential interference from a routinely perform intersystem interference analyses to as- proliferation of Ku-band non-geosynchronous orbit (NGSO) sess the ability of NASA systems to share the frequency very-small-aperture terminals (VSATs) has not been real- spectrum with other users and services. ized because these systems have not, as yet, been deployed, There is continuing demand for spectrum for mobile and NASA is reducing its use of S-band uplinks from its Deep voice, high-speed data, and Internet-accessible wireless ser- Space Network sites. vices that subjects NASA crosslinks and downlinks to po- tential interference from other services. Two examples are Recommendation: Although there is no compelling reason (1) the TDRSS crosslink and downlink and (2) the Deep for NASA to vacate the Ku band, it would be prudent for Space Network S-band uplinks. NASA to consider relocating its future Ku-band downlinks to a band with a primary allocation and to encourage users • TDRSS crosslink and downlink. T he TDRSS to transition from the Ku band to the Ka band. This approach downlink band is shared with government spaceborne active would provide insurance against unacceptable interference sensors on low-Earth-orbiting satellites, commercial Earth- arising from the future proliferation of commercial very- to-space very-small-aperture terminals (VSATs),14 and air- small-aperture terminal uplinks and could offer the second- borne,15 land-mobile satellite,16 and shipboard17 systems. ary benefit of a higher-capacity downlink. NASA has not experienced unacceptable interference from government spaceborne active sensors, and the Goddard Spectrum management is a long-term effort and com- spectrum manager negotiates agreements with commercial mitment, and NASA is diligently working through the NTIA, systems to protect the TDRSS downlink. In addition, por- ITU, and SFCG to protect its interests and implement the President’s Vision for Space Exploration.26 NASA has iden- tions of the band are protected by U.S. footnotes. While non- geosynchronous orbit (NGSO) systems are allowed to oper- tified three spectrum allocation deficiencies in forecasting its future requirements for radio frequency spectrum27 that ate uplinks in this band, which can potentially result in unacceptable interference to TDRSS, there are no opera- it would like to propose as WRC-2010 agenda items, and tional or known planned NGSO systems in this band. these goals and time spans are consistent with future pro- The TDRSS forward crosslink band is shared with com- gram needs and the national and international regulatory pro- mercial Earth-to-space uplinks; however, TDRSS is pro- cesses. tected by both ITU-R18 and U.S. footnotes.19 Although there has been some historical concern about Overall Capabilities increasing interference to the TDRSS forward crosslink20 and downlink, this interference has not yet materialized. NASA’s spectrum management work is comparable to
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36 REVIEW OF THE SPACE COMMUNICATIONS PROGRAM NOTES that performed by other space-faring nations and organiza- tions. NASA is a founding member of the SFCG. In com- 1. NASA (National Aeronautics and Space Administration), parison to the ITU Radiocommunication Bureau and Study NASA Electromagnetic Spectrum Management Policy Directive, Groups, the SFCG was established to provide a less formal NPD 2570.5D, October 17, 2005, available at http://nodis3. and more flexible environment for the solution of frequency gsfc.nasa.govdisplayDir.cfm?Internal_ID=N_PD_2570_005D_&page_ management problems encountered by member space agen- name=main. cies. 2. NASA, NASA Radio Frequency (RF) Spectrum Manage- ment Manual, NPD 2570.1, April 24, 2003, available at http:// Through its many years of effort in the SFCG, U.S. ITU- nodis3.gsfc.nasa.gov/npg_img/N_PR_2570_0001_/N_PR_2570_ R Study Group 7, and the NTIA, NASA has been successful 0001_.pdf. in promoting and preserving the allocation of spectrum for 3. NASA Spectrum Personnel, available at http://spectrum. its science missions. NASA has submitted several documents nasa.gov/about/personnel.aspx. to the ITU-R and SFCG addressing spectrum management 4. Struba, David, “NASA Spectrum Management,” briefing for missions to the Moon and Mars in anticipation of its fu- to the NRC Committee to Review NASA’s Space Communications ture exploration requirements. These include the definition Program, Washington, D.C., January 26-27, 2006. of frequency bands for human and robotic exploration of the 5. NASA, 2006 NASA Strategic Plan, NP-2006-02-423-HQ, Moon compatible with deep-space missions, other guidance available at http://www.nasa.gov/pdf/142302main_2006_NASA_ for spectrum management in the lunar region, a proposed Strategic_Plan.pdf. telecommunication relay network for Mars exploration and 6. NASA, NASA Radio Frequency (RF) Spectrum Manage- ment Manual, NPD 2570.1, April 24, 2003, available at http:// frequency assignment guidelines for communications in the nodis3.gsfc.nasa.gov/npg_img/N_PR_2570_0001_/N_PR_2570_ Mars region, and the initiation of recommendations for opti- 0001_.pdf. cal communications. 7. Struba, David, “NASA Spectrum Management,” briefing NASA civil service employees have significant experi- to the NRC Committee to Review NASA’s Space Communications ence and expertise in spectrum management. As an example, Program, Washington, D.C., January 26-27, 2006. a center spectrum manager worked in the Systems Review 8. Federal Communications Commission (FCC), General Branch (SRB)28 of the NTIA for several years and was the Guidance Document, U.S. Participation in the ITU Radiocommu- chief of the SRB during this period. Prior to his tenure in the nication Sector and in CITEL PCC II (radio communication in- NTIA, he worked in spectrum management for the DOD cluding broadcasting), November 18, 2003, available at http:// including the DOD spectrum management policy office. www.fcc.gov/ib/sand/irb/guidance.html. NASA employs the Arctic Slope Regional Corporation 9. NASA, Assessment of Commercial Alternatives to TDRS Services, Version 2, NASA Goddard Space Flight Center, Management Services (ASRCMS) and ITT as support con- Greenbelt, Md., December 2000. tractors. ASRCMS provides both national and international 10. NASA, NASA Electromagnetic (EM) Spectrum Manage- spectrum engineering support to NASA headquarters, and ment Policy Directive, NPD 2570.5D, October 17, 2005, available ITT provides international spectrum engineering support to at http://nodis3.gsfc.nasa.gov/npg_img/N_PD_2570_005D_/ NASA’s Spectrum Engineering Office located at Glenn Re- N_PD_ 2570_005D__main.pdf. search and other centers. Both contractors have significant 11. NASA, NASA Radio Frequency (RF) Spectrum Manage- spectrum management experience, and many of their em- ment Manual, NPD 2570.1, April 24, 2003, available at http:// ployees were previously employed by the FCC, State De- nodis3.gsfc.nasa.gov/npg_img/N_PR_2570_0001_/N_PR_2570_ partment, USAF, NASA, and the intelligence community. 0001_.pdf. Their personnel appear to provide excellent support to 12. NASA, NASA Long Range Electromagnetic Spectrum NASA, skillfully representing NASA interests at SFCG Forecast, Annex A, November 1, 2005. 13. NASA, NASA EM Spectrum Operational Plan, Draft, Feb- meetings, for example, and complement government capa- ruary 9, 2006. bilities. Both support contractors provide technical support 14. In FCC 05-14, the FCC noted that its database indicated in the areas of frequency coordination, interference analysis, that 2,672 authorizations were issued for GSO FSS Earth stations and preparation of documentation to support both national in the 14.0-14.5 GHz band. The authorizations indicate the maxi- and international meetings. In addition, they monitor new mum number of Earth stations or antennas that a licensee may de- national and international spectrum filings to determine if ploy. Since this is a very-small-aperture terminal (VSAT) band, a there is any potential impact on operational and future NASA single GSO FSS authorization could cover several thousand VSAT systems. Earth terminals. The committee visited GSFC as a representative center 15. In a 2005 Notice of Proposed Rulemaking, the FCC con- and found the equipment, facilities, and working environ- sidered adding a footnote to protect TDRSS; however, the FCC has ment similar to those of other government laboratories and not yet issued a final report and order. 16. Land-mobile satellite system users in the 14.0-14.2 GHz facilities. band are coordinated on a case-by-case basis through the Frequency Assignment Subcommittee of IRAC.
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37 SPECTRUM MANAGEMENT 17. Earth stations on vessels (ESVs) in the 14.0-14.2 GHz __data/assets/word_doc/9849/Radiocommunications_Spectrum_ (Earth-to-space) frequency band within 125 km of the NASA Re-allocation_Determination_2_2000.doc. TDRSS facilities on Guam or White Sands, New Mexico, are sub- 23. Australian Communications Authority, Radio-communica- ject to coordination through NTIA IRAC per the Code of Federal tions Spectrum Marketing Plan (2 GHz Band), Commonwealth of Regulations, Title 47, Volume 2, Section 25.222, “Blanket Licens- Australia, December 4, 2000, available at http://www. acma.gov.au/ ing Provisions for Earth Stations on Vessels,” CFR Citation acmainterwr/radcomm/spectrum_auctions/pdf_files/ 47CFR25.222, revised October 1, 2005, available from the U.S. marketing_plan.pdf. Government Printing Office via GPO Access at http://www. 24. Australian Communications Authority, Compatibility gpoaccess.gov/cfr. Assessment 2 GHz Deep Space Earth Stations with 3G Mobile 18. International Telecommunications Union (ITU), Radio Services, Spectrum Planning Report SP 09/01, Radiofrequency Regulations, Edition of 2004, Articles 5.502 and 5.503, ITU, Planning Group, June 2001, available at http://www.acma.gov.au/ Geneva, Switzerland, 2004. acmainterwr/radcomm/frequency_planning/spps/0109spp.pdf. 19. U.S. Department of Commerce, National Telecommunica- 25. Code of Federal Regulations, Title 47, Section 27.1134(d), tions and Information Administration, Manual of Regulations and “Protection of Federal Government Operations, Recognition of Procedures for Federal Radio Frequency Management, May 2003 NASA Goldstone Facility Operations in the 2110–2120 MHz Edition, January 2006 Revision, US Footnotes US337, US356, and Band,” CFR Citation 47CFR27.1134, revised October 1, 2005, US357, available at http://www.ntia.doc.gov/osmhome/redbook/ available from the U.S. Government Printing Office via GPO Ac- redbook.html. cess at http://www.gpoaccess.gov/cfr. 20. Wong, Yen, and Mark Burns, NASA/GSFC Ground Seg- 26. NASA, The Vision for Space Exploration, February 2004, ment Upgrades for Ka-Band Support to Near-Earth Spacecraft, available at http://www.nasa.gov/pdf/55583main_vision_space_ AIAA SpaceOps 2002 Conference, October 2002. exploration2.pdf. 21. NASA, NASA Long Range Electromagnetic Spectrum 27. NASA, NASA Long Range Electromagnetic Spectrum Forecast, Appendix 3, NASA, Washington, D.C., November 1, Forecast, Annex A, November 1, 2005. 2005. 28. The SRB reviews the spectrum requirements and compat- 22. Australian Minister of Communications, Information and ibility of all federal government systems that are submitted to the the Arts, Radiocommunications (Spectrum Re-allocation) Declara- NTIA Spectrum Planning Subcommittee. tion No. 2 of 2000, October 7, 2000, available at www.dcita.gov.au/