[SFDXA] ARRL Files Comments to Protect 70-Centimeter Amateur Band

[Bill]

    ARRL Files Comments to Protect 70-Centimeter Amateur Band

07/22/2025

ARRL The National Association for Amateur Radio <http://www.arrl.org/>® 
has filed comments with the Federal Communications Commission (FCC) to 
oppose part of an application that would impact the 70-centimeter 
amateur band for telemetry, tracking and command (TT&C) of satellites. 
The application, from AST & Science, LLC (AST), requests “unprecedented 
authorization to 430-440 MHz for a constellation totaling 248 satellites 
to communicate with five ground stations using up to five channels with 
up to 256 kHz bandwidth.”

READ ARRL’S FULL COMMENTS 
<https://www.arrl.org/files/file/FCC%20Documents/ARRL-Partial-Opposition-25-201.pdf> 
[PDF]

The formal opposition, filed by ARRL’s Washington Counsel, asserts that 
the permission AST seeks to use the 430 – 440 MHz band “should be denied 
because AST does not demonstrate need for TT&C spectrum beyond that 
available within existing allocations.”

The filing goes on to highlight just how unprecedented the request is:

/*The Requested Spectrum Is Not Allocated for the Requested Purpose*
The 430 – 440 MHz band is not allocated domestically or internationally 
for the requested space-to-Earth and Earth-to-space satellite TT&C 
operations. As others already have noted in this proceeding, signals in 
this band from AST’s current 5-satellite constellation have been 
observed throughout the world, including in the United States, 
notwithstanding that the satellites are authorized to communicate only 
with five ground stations well outside the United States. From the 
operations by the current five satellites, it appears that the 
satellites at times have transmitted continuously in the 430 – 440 MHz 
band throughout their orbit, not just when in communication with one of 
the authorized ground stations. This activity defeats the purpose of 
preventing interference in the United States by limiting operations in 
this band to ground stations distant from the United States. Authorizing 
an additional 243 satellites to use this band, which would result in 
multiple satellites over the U.S. at all times, would effectively usurp 
this band’s allocated use./

The 70-centimenter band is also used in emergency communications. As 
recently as early July, ARRL volunteers serving in the Amateur Radio 
Emergency Service® (ARES®) made headlines for providing critical 
communications in flood-ravaged areas of the Texas Hill Country 
<https://www.arrl.org/news/amateur-radio-volunteers-serving-during-texas-floods>. 
Allowing the 70-centimeter band to become overrun with TT&C operations 
could impact the ability for the Amateur Radio Service to be used in 
future disasters. “TT&C operations in the 430 – 440 MHz band are capable 
of causing harmful interference to radio amateur communications, 
including to amateur satellites operating in the 435-438 MHz subband,” 
the comments state.

The comments go on to outline why the application would be non-compliant 
with the ITU Radio Regulations Treaty.

Reply comments to the application are due by August 5, 2025. ARRL will 
continue to promote and protect amateur radio spectrum.

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