[NLRS] Fwd: ARLB023 ARRL to Oppose Proposal to Eliminate 3.3 - 3.5 GHz Amateur Allocation

[Jon Platt]

Thanks for the forward Matt.  It looks like under these two different proposals that we would lose the 3456 MHz band, and that 5760 would be further "shared".   
Regarding 5760, these two sections from the FCC proposal may illuminate the concern for those of us who operate at 5760.

16. The 5.850-5.895 GHz sub-band in the 5.9 GHz band is now especially well positioned todeliver immediate and potentially significant benefits when used by unlicensed devices and can help theCommission find new ways to meet the continued demand for spectrum access. Our proposal to add 45megahertz of 5.9 GHz spectrum that can be combined with the adjacent U-NII-3 band (5.725-5.850 GHz),if adopted, would provide a large contiguous block of unlicensed spectrum that could accommodate avariety of options—including two 80-megahertz Wi-Fi channels, four 40-megahertz Wi-Fi channels, or asingle contiguous 160-megahertz Wi-Fi channel.34 Further, because the 5.850-5.895 GHz sub-band isadjacent to the U-NII-3 band which supports unlicensed operations, equipment manufacturers should beable to readily and cost-effectively manufacture devices to expand operations into this sub-band.35 Weseek comment on how easily existing U-NII equipment could be modified to take advantage of theadditional 45-megahertz we propose here. 
17. We note that expanding unlicensed operations into the lower 45-megahertz portion of the5.9 GHz band would, in combination with the adjacent U-NII-3 band, also enable the first contiguous 160megahertz channel for U-NII devices that would not require use of dynamic frequency selection (DFS)interference mitigation technologies.36 Thus, we expect that equipment developed for the5.850-5.895 MHz band would be available sooner and provide users with superior performance as theequipment would not be subject to delays associated with development of complex test procedures toverify DFS operation, nor would it be subject to variations in available bandwidth due to the DFStriggering (which would affect throughput and reduce the amount of available spectrum at any giventime).37 Our proposal to make a 160 megahertz channel available for use without dynamic frequencyselection continues the U.S.’s role as an innovator and global spectrum policy leader. 


5760 in some higher density environments has already become unusable for weak signal work.

For those of us who chase VUCC, you only need 5 grids for a 3456 or 5760 VUCC, a very attainable goal even with 1 watt.  Get your 3456 and 5760 VUCC now (or in the next year or so) as they may become a collectors item.  If anyone needs some attainable grids on those bands, let me know and I would be glad to mount a gridExpedition.  
73, JonW0ZQ


-----Original Message-----
From: Matt Holden <mtholde at gmail.com>
To: NLRS Reflector <nlrs at mailman.qth.net>
Sent: Tue, Nov 26, 2019 9:58 pm
Subject: [NLRS] Fwd: ARLB023 ARRL to Oppose Proposal to Eliminate 3.3 - 3.5 GHz Amateur Allocation

QST de W1AW
ARRL Bulletin 23  ARLB023
>From ARRL Headquarters
Newington CT  November 26, 2019
To all radio amateurs

SB QST ARL ARLB023
ARLB023 ARRL to Oppose Proposal to Eliminate 3.3 - 3.5 GHz Amateur
Allocation

At its December 12 open meeting, the FCC will consider adopting a
Notice of Proposed Rulemaking (NPRM) that proposes to remove the
amateur radio 9-centimeter allocation at 3.3 - 3.5 GHz. ARRL plans
to comment in opposition to the proposed action. According to an FCC
"Fact Sheet," the proceeding WT Docket 19-348, "Facilitating Shared
Use in the 3.1 - 3.55 GHz Band," is a follow-on from the MOBILE NOW
Act, approved by the 115th Congress, which requires the FCC and the
US Department of Commerce to make available new spectrum for mobile
and fixed wireless broadband use. It also requires the FCC to work
with the National Telecommunications and Information Administration
(NTIA) to evaluate whether commercial wireless services and federal
incumbents could share spectrum between 3.1 and 3.55 GHz. NTIA
manages spectrum allocated to federal government users.

The Fact Sheet can be found online in PDF format at,
https://docs.fcc.gov/public/attachments/DOC-360941A1.pdf .

"This Notice of Proposed Rulemaking would propose to remove the
existing non-federal allocations in the 3.3 - 3.55 GHz band as a
step towards potential future shared use between federal incumbents
and commercial users," the FCC Fact Sheet explains. "By taking the
initial step needed to clear the band of allocations for non-federal
incumbents, the Commission furthers its continued efforts to make
more mid-band spectrum potentially available to support next
generation wireless networks - consistent with the mandate of the
MOBILE NOW [Making Opportunities for Broadband Investment and
Limiting Excessive and Needless Obstacles to Wireless] Act."

The NPRM proposes to clear the 3.3 - 3.55 GHz band of existing
non-federal users by removing non-federal secondary radiolocation
and amateur allocations [emphasis added] in the 3.3 - 3.55 GHz band
and to relocate incumbent non-federal users out of the band. The FCC
would seek comment on relocation options and "transition mechanisms"
for incumbent non-federal users, either to the 3.1 - 3.3 GHz band or
to other frequencies, and on how to ensure that non-federal
secondary operations in the 3.1 - 3.3 GHz band will continue to
protect federal radar systems.

Regarding the Amateur and Amateur-Satellite Service allocations, the
FCC NPRM asks whether existing amateur spectrum in other bands might
support operations currently conducted in the 3.3 - 3.5 GHz band.
The 3.40 - 3.41 GHz segment is designated 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 NPRM says.

Also at its December 12 meeting, the FCC will consider 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, and it would
continue as a secondary allocation, but the primary allocation for
5.850 - 5.925 GHz would change.

The amateur radio 5-centimeter allocation is 5650.0 - 5925.0 MHz,
and the NPRM, if approved, would address the top 75 MHz of that
amateur secondary band. While no changes are proposed to the amateur
allocation, anticipated more intensive use by primary users could
restrict secondary amateur use.

The band 5.850 - 5.925 GHz has been reserved for use by dedicated
short-range communications (DSRC), a service in the intelligent
transportation system (ITS) designed to enable vehicle-related
communications, the FCC said in a Fact Sheet in WT Docket 19-138.
"The Commission initiates this Notice of Proposed Rulemaking to take
a fresh and comprehensive look at the 5.9 GHz band rules and propose
appropriate changes to ensure the spectrum supports its highest and
best use." ARRL also will file comments opposing any changes
affecting the 5-centimeter amateur allocation.

This Fact Sheet can also be found online in PDF format at,
https://docs.fcc.gov/public/attachments/DOC-360940A1.pdf .

Both draft FCC proposals are subject to change prior to a vote at
the December 12 FCC meeting, and there will be opportunity to file
comments and reply comments on the final proposals after they are
released.
NNNN
/EX
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