Subj : Delta Division News
To : All
From : Daryl Stout
Date : Fri Dec 20 2019 05:27 pm
Greetings Delta Amateurs!
It is unfortunate that I must report that we have an immanent spectrum
threat now facing us. This potentially threatens ARES and other Mesh
networks and various mw users in this band. I send the following in part
from the ARRL website:
At its December 12 meeting, the FCC formally adopted a Notice of
Proposed Rulemaking (NPRM) in WT Docket 19-348 and invited comments on
its plan to remove "existing non-federal secondary radiolocation and
amateur allocations" in the 3.3 to 3.55 GHz band and relocate incumbent
non-federal operations. The FCC said it's seeking comment on appropriate
"transition mechanisms" to make that happen. ARRL has indicated that it
will file comments in opposition to the proposal. The amateur 9-centimeter
allocation is 3.3 to 3.5 GHz. The NPRM comes in response to the MOBILE NOW
[Making Opportunities for Broadband Investment and Limiting Excessive and
Needless Obstacles to Wireless] Act, approved by the 115th Congress to make
available new spectrum for mobile and fixed wireless broadband use.
"By proposing to delete the existing non-federal secondary allocations
from the 3.3 - 3.55 GHz band, we are taking an important initial step
towards satisfying Congress's directives and making as much as 250
megahertz of spectrum potentially available for advanced wireless
services, including 5G," the FCC said in the Introduction to its
NPRM.
Currently, the entire 3.1 to 3.55 GHz band is allocated for both
federal and non-federal radiolocation services, with non-federal users
operating on a secondary basis to federal radiolocation services, which
have a primary allocation, the NPRM explains.
The FCC said it is seeking comment on relocating non-federal licensees
to another band. With respect to amateur operations, the FCC invited
comments on whether sufficient amateur spectrum exists in other bands
that can support the operations currently conducted at 3.3 to 3.5 GHz.
The 3.40 to 3.41 GHz segment is earmarked for amateur satellite
communication. "We seek comment on the extent to which the band is
used for this purpose, whether existing satellites can operate on other
amateur satellite bands, and on an appropriate timeframe for terminating
these operations in this band," the FCC said. If non-federal licensees
are relocated to 3.1 to 3.3 GHz band, the FCC proposes that they
continue to operate on a secondary basis to federal operations,
consistent with current band allocations.
Some comments began to arrive before the FCC formally adopted the NPRM,
as it points out in a footnote. Kevin Milner, KD0MA, the
secretary/treasurer of the Ski Country Amateur Radio Club in Colorado,
has argued that the club's equipment cannot be re-channeled below 3.4
GHz, and the club is seeking relocation costs. Devin Ulibarri, W7ND,
told the FCC that amateur networks in the current band cannot move
easily into other amateur allocations because there is no readily
available commercial equipment to support the bandwidth, the FCC
recounted.
In the event the proposed amendments are adopted, the FCC "seeks
comment on relocation options and on transition and protection
mechanisms for incumbent non-federal operations."
Also at its December 12 meeting, the FCC considered another NPRM in WT
Docket 19-138 that would "take a fresh and comprehensive look" at
the rules for the 5.9 GHz band and propose, among other things, to make
the lower 45 MHz of the band available for unlicensed operations and to
permit "cellular vehicle-to-everything" (C-V2X) operations in the
upper 20 MHz of the band. The FCC is not proposing to delete or
otherwise amend the amateur allocation, which would continue as a
secondary allocation.
The Amateur Radio Emergency Data Network (AREDN) has offered its voice
in challenging the FCC proposals on the two bands, saying their adoption
would "eliminate our use of the most-effective resource hams have to
build its networks."
"The AREDN Project is able to leverage low-cost commercial devices
solely because they are designed to operate on adjacent allocations,"
AREDN said on its website. "Moving to other allocations would be
difficult if not impossible without a complete redesign, manufacture,
purchase, and installation of new custom amateur hardware and
software, raising the price out of reach for the typical ham."
Interested parties may file short comments on WT Docket 19-348 via the
FCC's Electronic Comment Filing Service (Express)-
https://www.fcc.gov/ecfs/filings/express
Visit the FCC "How to Comment on FCC Proceedings" page for
information on filing extended comments
-https://www.fcc.gov/consumers/guides/how-comment.
Please follow the instructions on the FCC site.
We should take any spectrum threat seriously!
73 ES GL
DE K5UZ
DE WB4RHQ
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ARRL Delta Division
Director: David A Norris, K5UZ
k5uz@arrl.org
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