[MAMS] Fwd: [NIMRODS] FCC Invites Public Comment on Petition Affecting 10-10.5 GHz Band

Fri Mar 21 18:14:25 EDT 2014

I'm trying to mobilize my fellow ham friends to take the time to comment 
to the FCC on this proposal allowing encroachment into the amateur 10 
GHz hamband by broadband Internet services.  While we have secondary 
status in this band, 10 GHz is probably one of the most populated 
microwave bands that hams are currently using.  This is because 
commercial equipment is bountiful and easy to convert for amateur use.

Some of the issues I see, would be the possibility of an increase in 
noise floor with an abundance of user equipment transmitters.  For 
example, my neighbor might be connected to this service and thus would 
have a very strong 10 GHz presence very near to my receiver.  These 
strong signals could block out the very weak signals we commonly are 
working on the band.  We use a variety of very weak signal modes, such 
as SSB and CW.  We also use somewhat exotic modes of propagation such as 
Tropo, Rain Scatter, Snow Scatter and Aircraft reflection.  Their 
equipment would most likely involve the use of omni-direction antennas, 
vastly increasing the possibility of my station receiving interference 
from multiple directions at once.

This sounds like a recipe for disaster to me, so I would request you 
comment to the FCC against this proposal.  You may not be using the band 
right now, but I would think you would want to preserve our ability to 
use this band in case you wanted to give 10 GHz a try at some time in 
the future.  Those of us utilizing the band have fairly substantial 
investments in our equipment, that could become very difficult to enjoy 
if this is allowed to come to pass.

Thanks for lending me your ear!

Scott,
N0EDV

http://www.arrl.org/news/fcc-invites-public-comment-on-petition-affecting-10-10-5-ghz-band

    FCC Invites Public Comment on Petition Affecting 10-10.5 GHz Band

03/14/2014
The FCC has invited public comment on a /Petition for Rule 
Making/ (*RM-11715* 
<http://apps.fcc.gov/ecfs/document/view?id=7022310834>), 
http://apps.fcc.gov/ecfs/document/view?id=7022310834 that would make a 
significant portion of the 10.0 to 10.5 GHz band available for wireless 
broadband services. The /Petition/ by Mimosa Networks Inc proposes a 
band plan for 10.0 to 10.5 GHz that, it says, would protect frequencies 
most often used by radio amateurs. The petition hinges on FCC adoption 
of rule changes that would put the 10 GHz band under Subpart Z of the 
Commission’s Part 90 rules. Subpart Z currently sets out regulations 
governing wireless licensing, technical standards, and operational 
standards in the 3650 to 3700 MHz band.
“[T]he application of the coordination procedures and requirements 
provided in Subpart Z will ensure that Amateur Radio operations in the 
band will not be disrupted,” Mimosa told the FCC. “In addition, as a 
further safeguard, Mimosa proposes a band plan for the 10.0-10.5 GHz 
band that would protect frequencies in the band that are most often used 
by Amateur Radio operators.” The proposed band plan would specify 10.350 
to 10.370 GHz as an “Amateur Calling Band,” and 10.450 to 10.500 GHz for 
Amateur-Satellite operations in the midst of 21 wireless broadband 
channels and a small guard band.
Mimosa has proposed to include in the rules a requirement for wireless 
broadband service operation in the band “to avoid harmful interference 
with Amateur service and Amateur-Satellite service operations in the band.”
In the international Table of Frequency Allocations, the primary 
allocation in Region 2 (the Americas) is to Radiolocation. Amateur Radio 
is secondary in the entire band, while Amateur-Satellite is secondary at 
10.450 to 10.500 GHz. In ITU Regions 1 and 3, the Fixed Service is 
co-primary; two “country footnotes” — essentially exceptions that 
individual countries have carved out in the allocations table — provide 
for primary Fixed and Mobile allocations in named countries, however. 
While these include Mexico and several other Region 2 countries, the US 
and Canada are not among them. Mimosa asserted in its /Petition/ that 
including 10.0-10.5 GHz under Subpart Z “would bring ITU Region 2 into 
alignment with Regions 1 and 3.”
“In Mimosa’s view, the coordination procedures and requirements provided 
in Subpart Z will ensure that Amateur Radio operators will be able to 
continue using the 10.0-10.5 GHz band as they do currently,” the company 
told the FCC, “without any disruption of their activities resulting from 
the Commission’s making the band available for wireless broadband services.”
Mimosa contended that its proposal would “promote the Commission’s goal 
of providing broadband access to all Americans, would benefit wireless 
Internet service providers, mobile wireless carriers, and 
telecommunications equipment providers, and would benefit the national 
economy.” Mimosa cited the band’s “long-reach, high-capacity 
characteristics” and called 10 GHz “a promising candidate for wireless 
broadband.”
ARRL Chief Executive Officer David Sumner, K1ZZ, said that while the 
League appreciates Mimosa’s efforts to acknowledge existing and growing 
10 GHz Amateur Radio activity, several aspects of the petition are of 
concern.
“Use of the band for fixed or mobile wireless broadband would be 
contrary to the international Table of Frequency Allocations and would 
inject a new sharing consideration that is not contemplated in the 
preparatory work being done for World Radiocommunication Conference 2015 
(WRC-15),” he said. “Mimosa’s proposed power limit of 55 dBW EIRP is 
very high, particularly for point-to-multipoint operations, and no 
mechanism has been proposed for ensuring that harmful interference to 
amateur operations does not occur.”
Sumner said that while the ARRL has not yet adopted a position with 
respect to the petition, “some aspects of the petition require careful 
study.”
Interested parties may comment on RM-11715 using the FCC’s Electronic 
Comment Filing System (*ECFS* 
<http://apps.fcc.gov/ecfs/hotdocket/list>), http://apps.fcc.gov/ecfs/hotdocket/list
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