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June 28, 2010 - ASCE Letter - on the Reallocation of the 1675-1710 MHz Band

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June 28, 2010

Marlene H. Dortch
Office of the Secretary
Federal Communications Commission
Room TW-A325
445 12th Street SW
Washington DC 20554

RE: ET Docket No. 10-123
Request for Information on Use of 1675-1710 MHz Band

Dear Ms. Dortch:

I am writing on behalf of the 144,000 members of the American Society of Civil Engineers
(ASCE) to recommend that the Federal Communications Commission (FCC) carefully assess
the potential problems associated with the possible reallocation of the 1675-1710 MHz band for
mobile uses.

According to the FCC’s public notice of June 4, 2010, the National Broadband Plan
recommends that the FCC reallocate at least 500 megahertz of spectrum available for
broadband use within the next 10 years. While ASCE recognizes that mobile Internet use has
doubled in the past two years and now totals more than 40 million users, we are concerned that
the proposed reallocation of the 1675-1710 band may have unfortunate consequences for
public health and safety.

The band is currently allocated to the National Oceanic and Atmospheric Administration
(NOAA). The agency uses it to receive weather data from radiosondes (weather balloons) and
weather satellite downlinks. The Administration seems to consider that this information, which
is used to predict floods and drought conditions in a timely manner, may be as beneficially
accessed through indirect transmission via the Internet or another means as by satellite.

The data transmitted by NOAA are used to ensure that the engineering of reservoirs, levees,
bridges, and other infrastructure systems are accurate and capable of protecting public safety
by preventing their failure in storm events. The data also are important in the operation of
reservoirs to ensure adequate drinking-water supplies and water for irrigation, navigation, and

The U.S. Geological Survey and NOAA use models and other tools that rely on the data from
the GOES system. A number of state water management agencies depend on the GOES
system for the transmission of their stream flow and diversion monitoring data as well.

ASCE believes that indirect distribution may slow the delivery of critical real-time data necessary
to manage natural disasters, particularly in times of Internet outages. Nor, we believe, does the
government know enough about the use of the band itself to make practical judgments about its

Thank you for considering our concerns over the proposed reallocation of the 1675-1710 MHz
band. Please do not hesitate to contact me at 202-789-7842 or at if we
can be of further assistance in this matter.

Sincerely yours,

Brian Pallasch
Managing Director
Government Relations and Infrastructure Initiatives