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

More convincing are the type of comments made on another forum a couple of weeks ago by Wayne @N6NB and Ed @W1RFI seen below (with emphasis added by me).

73, John, WØPV

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I would like to offer several arguments against eliminating amateur access to the entire 9 cm. band. I hope ARRL will use some of these arguments in opposing this proposal. I also intend to advance these arguments in my own comments and reply comments.

1) There is ongoing research into the characteristics of each VHF-UHF-microwave band under way and every band including 9 cm. is unique is some way. It was amateurs who first discovered the existence of long-distance tropospheric duct propagation over water. Amateurs John Chambers and Ralph "Tommy" Thomas first made a two-way contact from the U.S. mainland to Hawaii on 144 MHz via tropo ducting on July 8, 1957, demonstrating a new kind of propagation that had obvious implications for supposedly secure military communications.

Over the 62 years since then, amateurs have made trans-Pacific contacts by tropospheric ducting on 222 MHz, 432 MHz, 902 MHz, 1296 MHz, 2304 MHz, 3456 MHz and 5760 MHz. The paths and propagation characteristics differ on each of these bands.

I have personally been involved in propagation research on all of these bands, recently setting new world distance records on 902, 2304 and 3456 MHz while demonstrating that the conventional wisdom about the elevation of Pacific ducts was not entirely correct. If amateurs lose all access to 9 cm, this work will have to stop and the growth of knowledge of ducting at these frequencies will also stop. Even a single channel of 100 KHz with narrow guard bands would allow amateur research on 3456 propagation to continue. To pursue my research into duct propagation a 3.4 GHz, I made six round trips to Hilo, Hawaii in 2014, 2015 and 2016, carrying elaborate radio equipment on each trip.

2) There is extensive digital emergency communication via the AREDN network on the 9 cm. amateur band. If amateurs lose the entire band, this network will have to be shut down.

3) There are arguments to be considered about the equity of rendering amateurs' substantial investment in this band irrelevant. I have personally invested about $10,000 in transverters, amplifiers and antennas for the 9 cm. band. A single regulatory action could wipe out my entire investment and the investments of many other amateur licensees.

4) The League has a data base that will show the many hundreds of two-way contacts that occur on 3456 MHz during every VHF contest. Far from being little used, the 9 cm. band is heavily used during ARRL contests. ARRL has the data to prove that point.

These are a few of the arguments that could be made in opposition to a total removal of radio amateurs from the 9 cm. band. I offer them for ARRL's consideration.

- Wayne Overbeck, N6NB

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I would agree with Wayne that as a minimum, the weak-signal and HSMM functionality needs to be retained, at least in the approximate frequency range of our present allocation. Yes, we do have good documentation on many of the contacts made on 9 cm. There are more, and ARRL may be able to contact those that have made contest contacts on the band to ask what other communications they do, especially in the area of general scientific research. The HSMM use is NOT directly documented, but pretty important. In the AREDN network we are installing as part of the ARRL Lab operators club, W1INF, we want to use 5 GHz as the regional frequency and use 3.3 MHz for local connections within the building. This separation of frequency will minimize the "hidden transmitter" problems that may be encountered if we connect directly to the units being installed at 100 feet over local terraine.

- Ed Hare W1RFI

 

Only $10K?? Commercial lawyers will charge more than that combined in under an hour.

While I agree Wayne has made a big contribution to the band and that a narrow window should be preserved which includes EME and satellite comms, it is a very bad idea to wave pocket change as an argument.

Carl

 

It's great to see at least SOME verified use of the 9cm band. We all know this exists, but a more extensive presentation of use is needed. Essntially you need a 'spectral -use ' analysis, just like what other users of US freq allocations do.

This summary(above) is an assertion, not a data set.

Unfortunately this does not even remotely make the case for use of the ENTIRE 3300-3500 MHz allocation.

Failure to provide any sense of how MUCH bandwidth is used, and needed, for the activities described is taken ab initio as meaning that the view of Part 97 licensees does not consider the value of the allocation relative to its actual usage.

Its a good start, but likely far too late for any consideration.

Unfortunately, it seems to reinforce, IMO, the ARRL notion that it is unacceptable to request a 'carve out' --a smaller allocation for Part 97. The FCC commonly authorizes 'carve outs'. A great example is the additional 5G spectrum given to DISH.

Failure to present that is a big, big mistake.

You will lose the whole thing (entire 9cm band); the ARRL will be viewed as powerless in lobbying for ham radio; and 'spectrum defense' funds will be viewed as wasted money. Those are my opinions, yours may differ. Lobby for a piece of the pie, rather than lose the whole thing.

 

100 KHz, versus 200 MHz.

That's 2000 times the allocation needed.

 

In Arizona, we have several hams who are already operational on 3400 MHz (or who are putting together a system).
I (KJ7OG) plan to operate in terrestrial and EME activities. It seems that an "all or nothing" approach to keeping the band would be counterproductive. Keeping enough of the spectrum allocation without having to replace/redesign our existing equipment would be best, IMHO.
Steve KJ7OG

 

A well thought out carve out should have always been the objective. Trying to hold 200 MHz for amateurs is absurd.

The weak-sig propagation research and contest use is of course quite small bandwidth; I wonder how much the HSMM / AREDN requires.

Unfortunately, the best time to start lobbying for that would have been before the Mobile Now Act passed as part of HR1625 in 2018. That loaded the guns for the FCC and NTIA to now take serious action. But the League was apparently distracted and consumed with other matters during that time (sigh).

 

The AREDN folks need at least 5 MHz per channel. For a relay site, 10 MHz would be required.

 

It would be great if we can get some carve- out of the 200 MHz allocation, Steve.

IMO, asking for 20MHZ is not out of line, but that's an opinion. Others may differ.

If we don't ask, we won't get.

73
Chip W1YW

 

Hams barely use 2m 220mhz, 440mhz 900 etc and above that. I get it but as the old saying goes...use it or lose it.
All these dead repeaters every were and yall wonder why they want to sell off spectrum. Better get out there and use what we have, less we lose more.

 

Bring 40M out to 500 kHz and stretch 20 at both ends another 200 kHz total. Both are the real money bands from casual users to contesters....everybody wins from General and higher.

Maybe more on 17 which is quite active already.

Carl

 

Ignore the troll, fellow hams. We need to fight to keep our spectrum.

 

Honestly i think most people dont care. Whens the last time you used that band anyways? Who actually owns a radio that works there? I would love to see how many people do.

 

The CBRS band is 125 MHz of bandwidth just north of our 3.5 GHz band. It’s forecasted to be the beach front property of 5G. But unlike ever done before, it is “shared spectrum access” with incumbents, licensees and general access users all sharing the space. CBRS will make private LTE common place. Likely marketed as “OnGo”.

Why not make 3.3-3.5 GHz shared access too with hams as the incumbents? The beauty of this is the FCC can still sell commercial licenses. As an amateur, I would like to experience this new technology. Hams could run the Spectrum Access System same as Google was awarded to do for CBRS.

 

Certainly makes sense

 

we hams have a band up in freq that high??????? Never knew that. is propagation better there than 15 meters? Can I get was,dxcc there?