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

He was in April 2018, which was the date of those Minutes that I quoted from.

The point was that except for that little blurb, the ARRL seems to have been oblivious to the 3.4 GHz threat since before the Mobile Now Act was passed.

 

The CEO (current CEO) is obsessed with Business Jargon, not so much with leading the ARRL.

We will have "tribes" and "silos", but no 3.4 GHz band. .

 

Ron,

Not oblivious, but not action-oriented it would seem.

Again, we largely agree, and no need for us to knit -pick

The outcome to date (that is, how the ARRL will proceed and when) is just unacceptable, and the outcome moving forward has not been articulated to the membership.

What we SHOULD be seeing--now-- is a letter to all members with an alert and plan on 9cm...not a presumed early break for Christmas when concerned members , like K6CLS , follow thru.

Don't get me wrong: the rank and file employees work hard and are great people. They just need proper direction, resources, and marching orders.

I am very troubled that the ARRL may be losing its 'voice' with the FCC. I very much hope that I am wrong.

73
Chip W1YW

 

Agreed. I also think ARRL has been losing its voice with the amateur community.

I see this 3.4 GHz action as not only about saving the band or some peice of it. It is the ARRL's opportunity to pull itself back from the abyss; be smart, be unifying, and show some leadership. Maybe then the FCC might start taking the ARRL (and amateur radio in general) seriously again. The alternative is that if ARRL is weak and gets its butt kicked, this serves as a script for other interests to take down more of our GHz+ allocations in the future, even go after 23 cm and 70 cm.

 

Yes,

I believe your read is correct.

As an aside, it is ridiculous how this has panned out to date. Just look at the abuse I've had to put up with. Amazing...

What we REALLY should have had was the ARRL teaming with the AREDN folks for a fact-driven appeal to 'go to the polls', rather than a non-existent coalition that has the purpose of stopping the 'greedy carriers'.

Maybe that could still happen, but the calendar is against that successful execution IMO.

IMO we just looked like a bunch of dummies who can't agree on lunch. That, IMO, is exactly what other parties had hoped for, no matter what their motivation(s).

Your (all others) opinion may differ.

73
Chip W1YW

 

The first few Comments have been filed on ECFS since the final NPRM was released, most dealing with using 3 GHz band for emergency/backup communications during wildfires.

This brings up a technical question: Does 3.4 GHz have any particular advantage in heavy smoke, versus other frequency bands? If it does, the wildfire communications angle is a very good one, as it would argue against amateur activity being forced to move to other bands.

 

Yes it does--compared to 5 GHz.

There is a particulate issue that shows somewhat less attenuation in the sub 5 GHz range.

Perhaps someone can provide a reference on that--I am in no position other than to affirm that fact. I will not fuel false accusations of commercial interest--which I have already seen, and that are extraordinary and hurtful. Making those accusations makes me, personally, unwilling to volunteer beyond some limited scope.

A 3 GHz backbone is a strong but not unique reason for a carve out, although the allocation would be sub-MHz in size, IMO.

Users need to figure out what a viable carve out should be. The FCC will not suggest nor compose one. They will only assess. For example, if the FCC gets 10 different suggestions for a carve out, they will try to shoot each down individually, whereas a viable combination of options as one sub band may be defensible and thus accceptable. They will not try a compromise, as their position is the band is all disappearing at this time.

The FCC expects that any carve out has enough justification that it will not be shot down successfully by other users.

Present, justify, defend.

 

AREDN channels on 3.4 GHz are 5 MHz minimum. They can be as large as 40 MHz.

 

...and thus your mimimum carve out YOU request is....?

The point is that you have to explicitly spell out what the carve out needs to be, and I stress that asking for more than 20-25 MHz BW will be a non-starter.

Do not assume the FCC reads between the lines. You have to educate them on the needs, the specifications, the number of users, the uniqueness of benefit of the carve out, and so on.

Their fall back is that if no case is made then the default is adopted. The default is erasing the 9cm band from Part 97 use.

 

I would be happy with 10 MHz.

 

A good way to skin the cat is to demonstrate that the Mobile NOW requirement 'would not be materially degraded' if the Part 97 carve out was 10-25 MHz wide, for example.

This would leave 175 +MHz of bandwidth from the Part 97 (shared) allocation at present for the Mobile Now requirement. Compare that to allocations granted in the past, such as the fairly recent 600 MHz T-Mo allocation ( 84 MHz licensed by auction), or the far smaller DISH (14 MHz new allocation at 800 MHz).

175 MHZ is V-E-R-Y generous!

 

A possible avenue to a "carve out" would be to take advantage of a "duplex gap". For example, the 600 MHz band has an 11 MHz duplex gap at 652 to 663 MHz. Of course, this assumes that 3.4 GHz is allocated as an FDD band, and not a TDD band like CBRS.

 

BTW, the FCC is currently auctioning more millimeter wave spectrum. 3400 MHz at 37, 39 and 47 GHz.

https://auctiondata.fcc.gov/public/projects/auction103

 

The government doesn't trade, it takes. Government, once they start to take, will not stop till there is nothing left. You have way too much trust for "big brother".

 

That spectrum is not likely to be essential for USA 5G at this stage.

It may be more useful in 6G, where you have things like radar based autonomous vehicles and avoidance, universal IoT, and so on.

The US is really, from a network standpoint, a collection of city states with low capacity-need networks in between. That is different from Israel or Korea or even most of Europe. IOW you need to PLAN for the next generation--here-- before the NEED happens.

IOW big swaths of BW at mm don't solve the problem the US has now, or over the next few years.

73
Chip W1YW