[SFDXA] ARLB026 ARRL Seeks Changes in FCC Proposal to Delete 3.4 GHz Amateur Band

[Bill]

> SB QST @ ARL $ARLB026
> ARLB026 ARRL Seeks Changes in FCC Proposal to Delete 3.4 GHz Amateur
> Band
> 
> ZCZC AG26
> QST de W1AW  
> ARRL Bulletin 26  ARLB026
> From ARRL Headquarters  
> Newington CT  September 28, 2020
> To all radio amateurs 
> 
> SB QST ARL ARLB026
> ARLB026 ARRL Seeks Changes in FCC Proposal to Delete 3.4 GHz Amateur
> Band
> 
> ARRL met via telephone with FCC staff members this week to emphasize
> its opposition to the FCC Notice of Proposed Rulemaking (NPRM) in
> Docket 19-348 to delete amateur radio from the 3.3 - 3.5 GHz band.
> 
> The FCC will take final action in the proceeding when it meets on
> September 30.
> 
> The NPRM can be found online in PDF format at, 
> https://ecfsapi.fcc.gov/file/121661888341/FCC-19-130A1.pdf .
> 
> In comments filed earlier this year, ARRL urged that the secondary
> status for amateur radio in the band be continued. In a series of
> meetings with Commissioner legal advisors and staff members, ARRL
> explained how continued secondary use by radio amateurs will not
> impair or devalue use of this spectrum by future primary licensees,
> including those intending to provide 5G or other services. ARRL also
> stressed the various public-benefit uses of the spectrum by
> amateurs, including ongoing use of television and mesh networks on
> the west coast of the US as part of efforts to contain wildfires.
> 
> With regard to interference potential, ARRL stated that amateur
> radio operators using these bands are technically proficient and
> have a long history of sharing with primary users in this and other
> bands without causing interference.
> 
> FCC staff expressed concern that because amateur operations in the
> band are less clearly defined than those of other services also
> operating on a non-interference in the band, they would be difficult
> to locate should interference occur. ARRL Washington Counsel David
> Siddall, K3ZJ, noted that Section 97.303(g), an existing amateur
> rule, could be amended or used to craft a notification requirement,
> if the FCC concluded that relying on other methods would be
> insufficient.
> 
> The FCC participants indicated that such a requirement, in place of
> deleting the secondary allocation, would be given serious
> consideration. (Section 97.303(g) contains specific
> frequency-sharing requirements for the 2200- and 630-meter amateur
> bands.)
> 
> Siddall also pointed out that the Amateur Television Network (ATN)
> filed an email with the Commission that included a letter from the
> California Governor's Office of Emergency Services (Cal OES)
> describing amateur radio's contributions, specifically calling out
> the need for 3.4 GHz access and explaining why other bands are not
> sufficient.
> 
> ARRL also argued that, in any event, continued operation in the band
> should be permitted until and unless an actual potential for
> interference exists in a specific geographic area. ARRL said the FCC
> should not intentionally leave spectrum capacity unused during a
> build-out period that the Commission's own proposal indicates will
> last for at least 12 years in some areas.
> 
> The record in the proceeding is now closed. Please be reminded that
> there can be no calls, emails, or filings to the FCC with regard to
> the issues under consideration until a final FCC Report and Order
> and Further Notice of Proposed Rulemaking is released.
> 
> Release is currently expected to be within a few days after the
> Commission's September 30 meeting. At that time, ARRL will evaluate
> the impact on amateur radio of the Commission's decisions and
> consider what further action, if any, may be merited.
> NNNN
> /EX