FCC Notice of Proposed Rule Making: Hams to lose access to 3.3 - 3.5 GHz?

Ignore the trolls, folks. We need to fight this battle and WIN.

 

Again Brett--

I don't see any reason to FIGHT anyone.

We really would like to know more about you as you claim to take a leadership position in this act-ivity.

Have you ever operated as a Part 97 licensee on the 3300-3500 MHz allocation?

If so, tell us kindly what your operating conditions are, the frequencies within the allocation you use, and your general sense of 'why we need this band'.

Many thanks,
Chip W1YW

 

Most 5G will be initially targetted to where the people are in large numbers, such as cities, stadiums, schools, and so on. Eventually it will be everywhere. The easiest way to look at 5G at the moment is as an 'add-on on command'; phone calls in general will be 4G for example (where you don't normally need the bandwidth of 5G). Your phone will automtically invoke (in the future) when it needs the 5G bandwidth.

 

Brett,

Do you have a draft document for us to review?

I have my can of FRESCA and my RULER, but my bus leaves soon...

 

9cm has better propagation in the presence of rain and snow, and goes a bit farther in good weather, than 5 GHz due to lower absorption by oxygen. It isn't nearly as good as sub-GHz frequencies at penetrating foliage but is better at it than 5 GHz. The wavelength is short enough that high gain phased array patch antennas are very practical; a properly designed 19 dBi panel comes out about a foot square. My links which use 3 GHz spectrum have always been quite reliable.

 

This is confusing:

Are you a NON-HAM user of the 9cm spectrum, or do you use the 9cm allocation of Part 97 as a Part 97 licensee??

Brett, do you USE the ham radio 9cm allocation??

You obviously have access to equipment that is either able or modified for use on the 9cm Part 97 allocation--

ARE
YOU
A
USER
OF
THE
9cm
HAM
BAND

????

From what you have said so far, you seem to be --able-- to operate at the 3300-3500 MHz HAM BAND --but are not a USER of the 3300-3500 MHZ ham band. In other words, you seem to have the OPTION to use that band but see no benefit in doing so. That's how it looks, IMO.

Kindly clarify. IF you are a user of the band, we very much want to know your experience with it.

73
Chip W1YW

 

O2 absorption happens are far higher frequencies, not 5 GHz.

Perhaps you meant 50 GHz, which is still wrong, but closer.

 

Brett,

If the 3300-3500 MHz band was re-allocated (as all or most is likely the case) to the commercial carriers, how does that effect you in YOUR use of WISP ?

'WISP' stands for 'Wireless Internet Service Provider'.

Aren't you a WISP? Does this happen at anything around 3+ GHz for you?

Please fill us in on any issues that you see arising as a WISP if that 9cm band goes totally or partially 'carrier'.

Right now it looks like , for example, that WISP's might favor the use and continued allocation of the 9cm ham band because it is basically 'quiet space' for adjacent band or inside band use of WISP. But this needs clarity from a WISP operator such as yourself.

How would the re-allocation effect WISP?

Thanks!
Chip W1YW

 

This is bound to be helpful--for those interested in the atmospheric attenuation. It shows the dry (blue) and wet(red) atmospheric absorption. The first major absorption step is in the 22 GHz range...not surprising given that water vapor has a collisional molecular spectral line there...

Origin is the ITU report on atmospheric absorption. X axis is GHz.

The rise from, say, 2 GHz to roughly 15 GHZ is monotonic (on this dB scale) and not dominated by any spectral feature such as oxygen (there is no spectral line of oxygen there), and so on.

You can use this to show (or actually not show) why 3300-3500 MHZ is 'better'.... I think it is compelling evidence that it is 'not'.

BTW, Brett, notta lotta TREES in Laramie, at least when I last visited. So you don;t worry there about 'tree absorption' very much....

In fact, people paint MURALS of trees in Laramie to remind them what they look like!



73
Chip W1YW

 

The trolls are not only loud; they're ignorant. Moderators, I'd like to see an intelligent discussion of how to preserve hams' spectrum privileges that does NOT allow the trolls - posting loudly several times a day and attacking other members - to drive other potential participants from the thread. Could you facilitate this?

 

Brett,

All you have to do is ask me, and be nice. I assume you are not trying to prevent other people from disagreeing with you, no? I mean 'NOT allowing the "trolls" 'sounds like a suppression of legitimate opposing views.

I am happy to standby here and see how the additional comments play out. However, periodically,I will correct for factual reality. For example, your statement about absorption is absolutely incorrect and might unintentionally be misleading in any discussion of the use of alternative spectrum. Surely you agree that factual knowledge needs to drive this discussion.

If you would like to see that as a summary post of several points, sparingly,that's fine.

What's your pleasure?

Just let me know, here. In the meantime, I need to catch up on my pile of NATURES.

73
Chip W1YW

 

Brett seems reluctant to answer questions, but the information is easy to find by other means.

He operates his WISP in the 3550 - 3700 range MHz. He has a license for that. He has filed ECFS comments in opposition to previous NPRMs that affect that range, and I think his grounds for his opposition were not unreasonable. It is not clear to me, though, whether the current proposals concerning 3.30-3.55 GHz have any impact on his use of 3.55-3.70 spectrum.

So, barring any subtleties I didn't pick up on in the roughly 90 seconds of internet searching I did, I do not believe that his attitude on amateur 9cm has anything to do with his WISP business, if that's what you're wondering. He just seems to be a draw-a-line-in-the-sand-even-if-he-can't-win kind of guy. i.e. he'd be saying the same things no matter what frequency band was in play.

 

Hi Ron,

It seems to me he is capable of answering reasonable questions, so posed. That's what I did.

I do think you are missing an important point: if and when this band become part of 5G'mid-band', there may be certain IMD and 'purity of emissions' standards enforced against users in adjacent spectrum which, in this case, would be WISP (WISP is not limited to that band, BTW). IOW, WISP may then have to show certain certifications that are presently lacking.

IOW, WISP has skin in this game for its own reasons, not for ham radio 'solidarity'. MO.

I am of the opinion that WISP users very much want to maintain the ham radio 3300-3500 MHZ band as an adjacent band for their own benefit, as it is virtually empty, and the users of that band couldn't care less about noise floor issues from adjacent bands.

Having the empty 3300-3500 band as it is is like having a house between two empty large lots.

Finally saying 3300 is superior to 5GHz because of 'oxygen absorption' is the sort of comment that, if posed with the FCC, will make that response totally discounted as being posed on non-factual premises. It would be a damn shame if we missed a carve out because certain hams gave wrong info. There is nothing in any way disadvantageous in presenting the facts.

3GHz has minor advantages over 5 GHz because of the lamda squared dependence of the Friis equation, and a slightly less 'wet' absorption in attenuation. The larger antennas for a given gain countermands some of the lambda squared Friis dependence: making larger antennas for 3 Gig is expensive, non- aesthetic, and has higher wind load. BTW, anyone who expects 3 OR 5 GHZ to go through a forest of trees -well--just doesn't know enough about microwave, IMO.

Hope that helps.

Suppressing other opinions that are fact based is a typical activist ploy. Its what got Mizzo (U.MO.) a huge decline in enrollments, for example.

Enough. I very much want to see if someone actually pulls something together and gets fact checking in the process.

Carry on.

73
Chip W1YW

 

3300 to 3500 MHz isn't exactly empty. Here's the NTIA spectrum usage report. I can see why they were suggesting 3450 to 3550 MHz. If we're lucky, maybe they'll put their foot down and stick with that recommendation.

https://www.ntia.doc.gov/files/ntia/publications/ntia_quant_assessment_report_appendices.pdf

 

If it was seen as 'full'. we wouldn't be discussing this.

I agree; stick with the rec!

73
Chip W1YW