APT comment to consultation final

APT SATELLITE CO., LTD 22 Dai Kwai Street, Tai Po Industrial Estate, Tai Po, NT, Hong Kong Tel: (852)2663-3038 Fax: (852)2666-7838 April 17, 2009 Mr. T. F.So RSAC Chairman Radio Spectrum Advisory Committee (RSAC) Office of the Telecommunication Authority (OFTA) 29/F, Wu Chung House 213 Queen’ s Road East Wanchai Hong Kong Re: Comment on Consultation Paper Creation of a Class Licence for Ultra-Wideband Radiocommunications Devices under Section 7B(2) of the Telecommunications Ordinance (Cap. 106) Ref: Report on Consultancy Study in relation to Electromagnetic Compatibility of Ultra-wideband Radiocommunications Devices” issued by OFTA in 21 January 2009, referred as “ the report” Dear Sir, APT Satellite Company Limited is one of the satellite operators in Hong Kong that would be a major victim of the deployment of UWB service in 3.4 GHz to 4.2 GHz band. The analysis and test detailed in the report have fully proved there is interference from UWB service to FSS. Whether the interference is harmful or not harmful, acceptable or not acceptable is up to further discussion in the current stage. We refer to OFTA s paper on below 3 issues as: (a) Whether UWB radiocommunications devices should be allowed for use in Hong Kong at this stage APT notes that, no matter OFTA issues UWB license to its users or not, there are more and more UWB devices or applications flowing into Hong Kong IT market. Rather than let it grow out ...