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

In rural areas like ours, we're so far from the the Central Office, the lines are on amplifiers. So if power goes out, the landlines go down.

The FCC has already gotten the local OTA TV broadcasters to relocate their transmission frequencies for to give more spectrum to the telco's. Which is my opinion, is a total waste of time, given that most of the OTA TV stations in this area are Canadian.

The FCC would be hard pressed to re-allocate the microwave oven band if NAB puts up a fight. Both law enforcement and commercial TV use 2.4-2.5 GHz for transmitting video LOS.

The adjacent amateur bands are low hanging fruit for the telco's. There is already an overlap at 2.305 - 2.310 GHz.

Prolonged power outages in the Northeast have occurred, especially during winter ice storms (freezing rain).

Supporting served agencies by transmitting documents such as maps, photos, lists on LOS links during a prolonged power outage is a capability that needs to be maintained.

In my opinion, the amateur bands near 2.4 GHz will soon be vulnerable as well.

 

FYI--Here is the (existing) 2012 ARRL band plan for 9 cm.
I plan to submit to both ARRL and to FCC my comments regarding a request to have a "Carve-out" of the band.
Steve KJ7OG

 

Canadian TV stations will be repacking too. The timetable is a bit longer though and extends to 12/03/2021.

https://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf11282.html

 

While not solicited, I'd like to jump in here. First of all, I want to thank those that have submitted meaningful comments on this important QRZ forum topic. ARRL FCC Counsel Dave Siddall, K3ZJ is preparing an ARRL response to NPRM 19-130, and to another proposal that will have a profound effect to our secondary allocation on 5.9 GHz, and this is all good information to feed him when we meet in a couple of weeks at the ARRL Board meeting. Yes, somebody is watching.

I will agree with those that have commented on this forum that it seems the ARRL has been caught flatfooted, and there's really no excuse for it. As a fairly new ARRL Director, all I can say is that it wasn't until the AREDN people here in Washington state brought this to my attention that I even knew of these severe spectrum threats. The ARRL either was focused in the wrong direction, or did not understand the profound effect of losing this band, or both. One of the amateur radio missions listed in Part 97 is EmComm, and the 3.3 and 5.9 GHz AREDN/HamWAN networks are currently being developed and deployed all over the country to support that mission. Bringing in new STEM kids into the amateur radio fold is going to take microwave IP technology for them to play with, and that's where the heart of all this equipment is. Believe it or not, this will be a much bigger threat to the hobby twenty odd years from now than overcrowding of CW ops on 40 meters will be by then.

With a new Board in place and perhaps other changes next month, I would expect a more outward focused board and ARRL going forward. We need to do better. Thanks again.

73;
Mike
W7VO (Director, NW Division)

 

W7VO Mike,
I am a bit confused about two FCC NPRMS for needed commenting. They are NPRM 19-130 and 19-138.
For 9 cm comments, which NPRM is appropriate, and when do we have a deadline for submitting comments.
Thanks, Steve Bell KJ7OG

 

Mike,

I don't see anything in your comments that translates to compelling justification for keeping any or part of the 9cm band. This is worrisome--it propagates the 'hope' versus 'Evidence--Purpose-Justification' approaches.

You should ask around the board to see if: 'Cohen knows what he is talking about'. I've done everyone a HUGE favor by alerting folks here what works, and what doesn't. I am not seeking the ARRL's attention and, in fact, would decline if asked further. Fred, K1VR, has similar views to mine, I imagine (we have not discussed the NPRM). Listen to him.

AREDN, as presently configured, has not made a case that requires a 9cm 'carve-out' for it to execute Part 97 mission: the case has not been shown that use at 9cm is UNIQUELY ENABLING for Part 97. The ARRL and AREDN need to show that executing that mission CANNOT work at other bands. AREDN is a great organization and tech savvy group, but the issues now transcend merely 'being there'.

STEM will not save 9cm. STEM works on 'other bands'. STEM as Part 97 mission is not ENABLED by 9cm. Making that assertion translates to instant push-aside. Did you NOT see that the FCC will dessicate the experimental licences on 9cm?? Many of those --ARE-- STEM.

If the ARRL fails to justify a carve-out on 9cm, the probability of losing more spectrum in coming years is, IMO, dramatically higher because the ARRL will not have the credibility needed to work the solution.

Don't place the onus of this on K3ZJ's shoulders--he will do the best he can with the limited amount of supportive data that's available from a disparate group of sparse users.

The ARRL has known about these issues for years. Heck, I personally discussed it with K1ZZ and N4QX! It fell apart when N4QX was 'retired' out to save money. This would not have happened with Brennan in place.

And Mike-- don't get cutesy about the 'other changes'. We don't need that tease or desire to read between the lines. Either 'fess up or be quiet.

I see you are trying to come up to speed with the issues. That's very good. Figure out how the FCC works and what justifies spectrum. Be careful about shooting the messenger...you might end up shooting at your foot;-)

73
Chip W1YW

 

No Mike--

5 years, not 20. There will be rapid and dramatic loss of Part 97 microwave spectrum if we do not make the case for a 9cm carve-out now.

73
Chip W1YW

 

Mike W7VO,

I can see I was being overly harsh on you vis a vis 'cutesy'. Looking at this, I don't think I was being helpful with this comment, and my apologies.

The fact that the FCC on 12 Dec essentially eradicated the 9cm band means that the priorities of the 'National Association of Amateur Radio' ARE out of line with reality with continuance of Part 97.

The ARRL board made a decision over a year ago to hire a CEO whose predicated MO is "fail fast". I would rate the 9cm actions to date as a major failure. But ultimately its the BOARD that is responsible for strategy, before execution. The board has to get in the mind of a group of FCC lawyers who have been heavily-handed told to find spectrum under MOBILE NOW. These folks are neither arbitrary nor capricious. They need to show compelling justification for why secondary users need 9cm spectrum--uniquely-- for executing Part 97 mission. Things that SOUND nice-- like potential innovation, STEM, a couple of hundred contacts in VHF contests, and so on, are meted against the fact that there are over 750,000 Part 97 licensees who virtually are non users of the 9cm band.

AREDN and the like has real meat to it, but the 'unique use' case at 9cm is not at all clear.

Responding to 9cm on the NPRM is a saddle point for the ARRL. THINK like an FCC commissioner, and not a ham; that is my advice in responding.

I have given a great deal of helpful advice on responding, which I am certain is well known at this point. Its too bad that failure to act ahead, as I suggested to ARRL management many times and for quite a while, has not born fruit: That, and the highly public abuse I was subject to for articulating an obviously unpopular but necessary subject of band loss are the reasons why I will not actively participate on this issue . I will advise, but not respond.

73
Chip W1YW

 

There's nearly more 'band plan' than unique users! I mean really: 100 MEGAHERTZ of separation for TX/RX!

This is what you show if you have 200 MHz of bandwidth.

No one will buy into modulation modes that needs 50-100 MHz for use. That's just an artificial construct of the PRC manufactured radios--not designed for ham radio!

Re-do the bandplan with 20 or 25 MHz of bandwidth in toto. That will be your carve- out.

 

I looked up the Federal Register listings for FCC documents and found this:
https://www.federalregister.gov/doc...-commission-meeting-thursday-december-12-2019

Topics mentioned are on Docket 19-138, and includes mention of the 3 Ghz and 5 Ghz bands.

The Fed. Register publication date was December 18, so I would guess that comments must be submitted within 30 days to be accepted.

 

Headlines and comments from a recent Bloomberg article...

C-Band Analyst Says Spectrum Sale May Net $50 Billion in Revenue.
That positive view stems from Taiwan’s recent auction of the 3.5GHz band, where New Street said the bids were “blowing away expectations.”

https://www.bloomberg.com/news/arti...may-net-50-billion-in-revenue?srnd=markets-vp

 

The FCC has announced that the Comment period will close February 21

See: ARRL to Argue for Continued Access to 3-GHz Spectrum as FCC Sets Comment Deadlines

 

Ron,

Do you have the handy link for reading the extant comments?...I seem to have misplaced it.

73
Chip W1YW

 

Proceeding 19-348 (3.1-3.55 GHz): https://www.fcc.gov/ecfs/search/filings?proceedings_name=19-348&sort=date_disseminated,DESC

Proceeding 19-138 (5.850-5.925 GHz): https://www.fcc.gov/ecfs/search/filings?proceedings_name=19-138&sort=date_disseminated,DESC

 

NTIA report on 3450 to 3550 MHz sharing.

https://www.ntia.gov/files/ntia/publications/1-24-2020_ntia_tr-20-546.pdf