HR2.0 - Spectrum Defense: FCC Proposal to Remove Privileges on 3/5GHz

Discussion in 'Amateur Radio News' started by KC5HWB, Dec 24, 2019.

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  1. KC5HWB

    KC5HWB Premium Subscriber QRZ Page

    Special thanks to David, KB5UGF for bringing this information to me and asking me to record a video on it. The FCC has proposals submitted to remove Ham Radio privileges from the 3GHz and 5GHz bands, which are vital to AREDN Mesh Networks, BBHN Mesh Networks, HamWan and many other systems already in place. Watch this video, put your comments below and check this important links to see how you can help with the Spectrum Defense of the 3GHz and 5GHz bands.

    ⚑ Andre K6AH has prepared instructions and templates to assist you in submitting your comments on the 3 GHz FCC Docket 19-348. You can find these in the Forum posting https://www.arednmesh.org/content/templates-submit-comments-3-ghz-fcc-docket-19-348

    ★★★ FCC Proposal Documents: ★★★
    ⚑ WT Docket No. 19-348 (concerns the 9 cm band): https://docs.fcc.gov/public/attachments/DOC-360941A1.pdf
    ⚑ WT Docket No. 19-138 (concerns the 5 cm band): https://docs.fcc.gov/public/attachments/DOC-360940A1.pdf
    ★ FCC Comment Links: ★
    ⚑ How to comment: https://www.fcc.gov/consumers/guides/how-comment
    ⚑ Short on-line comments here: https://www.fcc.gov/ecfs/filings/express

    ★★★ ARRL Spectrum Defense Fund: http://www.arrl.org/spectrum-defense-fund


     
  2. W1YW

    W1YW Ham Member QRZ Page

    FYI--

    Just saying 'its ours don't take it away from us!' will have zero positive impact in the decision.

    Don't go after 5GHZ---concentrate right now on the 9cm band....

    Here's what MIGHT work:

    1) Address the 200 MHz re-allocation as a whole, as not esssential to enhance the Mobile NOW initiative; a material difference does not exist between, say, a 180 MHZ versus 200 MHZ allocation;

    2) Stress extant users of Part 97 USING THE 9 cm BAND and needing a 'carve-out'. Combine the full 9cm Part user community in requesting and defining the 'carve-out'. Define the carve-out with 'one voice'. Don't suggest different variations--each will be attacked separately. A collective specific suggestion will not be so treated.

    The probability of a carve-out dramatically decreases when the request exceeds 20 MHZ, IMO;

    3) Emphasize that the Part 97 mission would be impeded with a loss of the entire (in toto) 9cm band --and usurping it without justification is contrary to the mission of Part 97. Emphasize FACTUAL ( be SURE your FACTS are cited; incorrect info will DISCOUNT the comments entirely from credible consideration!) benefits to a 9cm allocation for Part 97 that cannot be replicated in other bands, such as 5GHz.

    4) AREDN is a great asset, but in itself it will not in any way lead to keeping the full 200 MHZ allocation. AREDN needs to work with others in defining a carve-out.

    For reasons fully and publicly stated--based on abusive and public attacks against me over 15 years on this issue of losing Part 97 allocations-- I will NOT personally get involved. Consider the above advice a gift of assistance in lieu of participation.

    73
    Chip W1YW
     
    Last edited: Dec 24, 2019
    NN4RH likes this.
  3. W1YW

    W1YW Ham Member QRZ Page

    Below is FICTIONAL answer---not an actual response-- that captures the likely character of response that the FCC will use at the conclusion of the NPRM. Use as foresight to address these issues--and prevent the FCC from turning down a carve-out...

    Checking a form for responding is better than nothing, but does not address the 'uniqueness' and 'need' issues.

    AREDN and BBHn and HAMWAN are wonderful and important initiatives that deserve 9cm spectrum IF the case for uniqueness and need are made.

    --------------------------------------------------------------

    The xxx has fully considered the comments submitted by the amateur radio community, and others, regarding future use of the 3300-3500 MHz band. The xxx reminds radio amateurs that the prior use of the ‘9cm band’ was on a secondary basis and that prior interest in the 9cm band has not deviated from this secondary use.


    Keeping the entire, or part of, the 3300-3500 MHZ allocation for Part 97 must present a compelling case for need. The Mobile Now initiative has a clear case for need, and this 9cm allocation best meets those needs, at least in part, in a timely manner. In considering whether radio amateurs would best be served by a partial allocation (a ‘carve-out’) within that band, the xxx is guided by the mission of Part 97. It is noted that the bulk of amateur radio activity is ‘hobby oriented’ and does not focus on the Part 97 mission. The xxx recognizes that the small number of radio amateurs that use the 9 cm band are undertaking the Part 97 mission and are commended for doing so. We encourage that further activity of mission. However, in no case have we seen compelling data and nor examples (most of which are anecdotal and represent a scant <<0.1% of the Part 97 license pool) that demonstrate radio amateurs require any allocation at 9cm. There is no unique activity within the Part 97 mission that cannot be done by this small pool of Part 97 licensees at other Part 97 allocations. The comments do not demonstrate that unique need.


    The xxx recommends adherence to the NPRM guidelines, removing the 9cm band from Part 97 use.

    -------------------------------------------------------------------

    73
    Chip W1YW
     
    Last edited: Dec 24, 2019
  4. W1YW

    W1YW Ham Member QRZ Page

    Some helpful comments specifically on the video and its call to action---

    Defensive assertions that will NOT work for 9cm—

    1) Stating that 3300-3500 only recently became ‘usable’ because of the recent availability of commercial equipment (read: ubiquti-Chinese manufacture) that could be modified by hams. Man, that is a can of worms. From a Part 97 standpoint this is the REVERSE of mission—hams should be developing the gear that THEN later sees commercial spinoffs. There will no sympathy for ‘I couldn’t buy it until now’ arguments. Especially if it was made in the PRC!;

    2) Making statements about ‘development’ of networks….have you found something that is BETTER than extant waveforms and systems? That would be awesome…but without evidence of something new and better, this will be viewed, at best, as a ‘me too’ approach. IOW are we following, or leading, in Part 97 for the ’enhancement of the radio art’? Furthermore, the FCC may argue that it gives copious experimental licenses already for that purpose.

    3) Calling it a ‘battle’ or ‘fight’. The FCC will not be sensitive to our ‘feelings’ and our naïve allusions to a war or conflict. They want evidence and purpose and justification (EPJ). If you want to use that analogy, then give EPJ as ‘ammunition’.

    4) Reporting tornadoes-- that is a scare tactic that can work against us. You need to explain why reporting tornadoes on Part 97 mesh networks at 9cm is essential, as opposed to some other band, even 70 cm for example.

    5) ‘Supporting agencies’—great stuff, but the FCC will separate out the SUPPORT from the ALLOCATION. Why—must—it—be—at—9cm?

    6) That the ‘fight’ is between big Telecom lawyers and our underfunded SDF at ARRL. Money does NOT solve or resolve this issue at 9cm to our Part 97 advantage. EPJ does.

    Hope this helps.

    I fear that if the ARRL makes this a passion play that the future ramifications will be unbounded for both Part 97 spectrum loss and the ARRL future. Showing need and justification for a well thought out 'carve-out' makes sense.

    E--P--J

    73
    Chip W1YW
     
    Last edited: Dec 25, 2019
  5. W1YW

    W1YW Ham Member QRZ Page

    Good advice Brett!

    It's important that ham operators go into this with as much information on FACT and PROCESS as possible. Trying to see, and anticipating, how the decisions are made is key to putting your best foot forward.

    I am glad I was able to contribute. Remember: E-P-J.

    HNY

    73
    Chip W1YW
     
  6. W1YW

    W1YW Ham Member QRZ Page

    Notta 'defense'. We don't OWN it , Brett. Heck, 9cm as an allocation was SHARED for goodness sake!

    We are licensed for privilege of use, NOT ownership.

    E-P-J....

    Evidence and Purpose and Justification

    That's the only way that we can get a carve-out. Otherwise it will ALL go away as planned to date in the NPRM.



    [​IMG]
     
    Last edited: Dec 25, 2019
  7. W1YW

    W1YW Ham Member QRZ Page

    Ron,

    For more than a month, Brett Glass, WY7BG, has railed against the carriers on the Zed, as having "greed that knows no bounds" and asserting that we Part 97 amateurs need to form a coalition with others to "fight" them to "defend our spectrum".

    The problem is US
    , and how we use(or don't use) our spectrum-- and how we present ourselves.

    We have all been waiting to see Brett's plan, or at least a draft.

    So...where is it??

    Time is flying . If Brett has something positive that will help, it certainly would be welcomed by all, including me.

    I've done my part by enlightening the perspective that most likely will be the same or similar to the decision process at the FCC. Knowing that is key to getting a positive reponse to presented comments to the NPRM.

    It is hurtful and abusive to characterize me and my comments as (a) "troll". That just doesn't belong here, and at this critical moment, in what could be a turning point in all future Part 97 allocation decisions. Another case of: 'no good deed goes unpunished'.
    73
    Chip W1YW
     
    Last edited: Dec 25, 2019
  8. NN4RH

    NN4RH Premium Subscriber QRZ Page

    It also should be borne in mind that this is not just the run of the mill FCC proceeding. The FCC, via the NTIA, has to report to Congress on this. So not only does the Amateur Radio Service comments have to EPJ to the FCC, but has to be done in such a way that the NTIA, when they report to Congress, also will support keeping ARS on these frequencies, and when Congress gets the report, it has to convince them that their mandate for GHZ spectrum can be met, while keeping ARS on these frequencies, as well.

    So in my mind, rants about "oligarchy of greedy carriers" is not going to do it. Heck, Congress WANTS an "oligarchy of greedy carriers".

    Having read some comments posted so far, a lot are of the "I am opposed ..." type, with little or no explanation of why. It's great that we're opposed, and we should be, but I think the FCC already would have guessed that. It's not a vote! They are looking for reasons EPJ not to do what they propose, not whether we like it or not.

    And a nit, many refer to HAM, ham, Ham, etc. This degrades the cause because it conjures up images of hobbyists fiddling around in a crowded radio shack, which IMO don't stand a chance against an "oligarchy of greedy carriers". The term "Amateur Radio Service" or "Part 97 licensed service", etc, would be preferable to Ham, ham, HAM etc., in my view.

    A few cancel themselves out by insisting that amateurs can not be moved ... and then in the next sentence say, basically, give us money and we'll move. It might be more effective to file two comments - one making a technical argument why what you're doing can only exist in 3.3-3.5 GHz - and a separate one arguing for compensation.
     
    Last edited: Dec 25, 2019
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  9. NN4RH

    NN4RH Premium Subscriber QRZ Page

    And doing grammar, punctuation and spell checking on the Comments before submitting them would not hurt.

    A sloppy Comment sends the message that the 3.4 GHz band is not important enough to spend a few minutes composing a well-written one..


    IMO.
     
    Last edited: Dec 25, 2019
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  10. WY7BG

    WY7BG XML Subscriber QRZ Page

    Looks as if I should have used the plural.
     

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