[Mich VHF UHF Society] [DigitalATV] The ARRL Seeks Changes in FCC Proposal to Delete 3.4 GHz Amateur Band

Ron Economos w6rz at comcast.net
Mon Sep 28 02:34:21 CDT 2020


Since only 3450 to 3550 MHz will be reallocated at first, the Further 
Notice of Proposed Rulemaking discusses amateurs keeping access to the 
lower portion of the band. See paragraphs 66 through 70. 3300 to 3400 
MHz is suggested, but they're requesting comments on exactly where the 
split should be.

https://docs.fcc.gov/public/attachments/DOC-366780A1.pdf

Ron W6RZ

On 9/27/20 21:54, Mark Thompson via groups.io wrote:
>
> *The ARRL Seeks Changes in FCC Proposal to Delete 3.4 GHz Amateur 
> Band* 
> <http://www.arrl.org/news/arrl-seeks-changes-in-fcc-proposal-to-delete-3-4-ghz-amateur-band>
>
>
>     ARRL Seeks Changes in FCC Proposal to Delete 3.4 GHz Amateur Band
>
> 09/26/2020
>
> ARRL met via telephone with FCC staff members this week to emphasize 
> its opposition to the FCC /Notice of Proposed Rulemaking/ (*/NPRM 
> <https://ecfsapi.fcc.gov/file/121661888341/FCC-19-130A1.pdf>/*) in 
> Docket 19-348 to delete amateur radio from the 3.3 – 3.5 GHz band. The 
> FCC will take final action in the proceeding when it meets on 
> September 30.
>
> In *comments* 
> <https://ecfsapi.fcc.gov/file/1022206574631/ARRL%20WT%2019-348%20Comments_02_21_2020.pdf> filed 
> earlier this year, ARRL urged that the secondary status for amateur 
> radio in the band be continued. In a series of meetings with 
> Commissioner legal advisors and staff members, ARRL explained how 
> continued secondary use by radio amateurs will not impair or devalue 
> use of this spectrum by future primary licensees, including those 
> intending to provide 5G or other services. ARRL also stressed the 
> various public-benefit uses of the spectrum by amateurs, including 
> ongoing use of television and mesh networks on the west coast of the 
> US as part of efforts to contain wildfires.
>
> With regard to interference potential, ARRL stated that amateur radio 
> operators using these bands are technically proficient and have a long 
> history of sharing with primary users in this and other bands without 
> causing interference.
>
> FCC staff expressed concern that because amateur operations in the 
> band are less clearly defined than those of other services also 
> operating on a non-interference in the band, they would be difficult 
> to locate should interference occur. ARRL Washington Counsel David 
> Siddall, K3ZJ, noted that Section 97.303(g), an existing amateur rule, 
> could be amended or used to craft a notification requirement, if the 
> FCC concluded that relying on other methods would be insufficient. The 
> FCC participants indicated that such a requirement, in place of 
> deleting the secondary allocation, would be given serious 
> consideration. (Section 97.303(g) contains specific frequency-sharing 
> requirements for the 2200- and 630-meter amateur bands.)
>
> Siddall also pointed out that the Amateur Television Network (ATN) 
> filed an *email* 
> <https://ecfsapi.fcc.gov/file/10924040735543/ATN20FCC20Parte20Sept.2C%202020.pdf> with 
> the Commission that included a letter from the California Governor’s 
> Office of Emergency Services (*Cal OES 
> <https://www.caloes.ca.gov/>*) describing amateur radio’s 
> contributions, specifically calling out the need for 3.4 GHz access 
> and explaining why other bands are not sufficient.
>
> ARRL also argued that, in any event, continued operation in the band 
> should be permitted until and unless an actual potential for 
> interference exists in a specific geographic area. ARRL said the FCC 
> should not intentionally leave spectrum capacity unused during a 
> build-out period that the Commission’s own proposal indicates will 
> last for at least 12 years in some areas.
>
> The record in the proceeding is now closed. Please be reminded that 
> there can be no calls, emails, or filings to the FCC with regard to 
> the issues under consideration until a final FCC /Report and 
> Order/ and /Further Notice of Proposed Rulemaking/ is released. 
> Release is currently expected to be within a few days after the 
> Commission’s September 30 meeting. At that time, ARRL will evaluate 
> the impact on amateur radio of the Commission’s decisions and consider 
> what further action, if any, may be merited.
>
>
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