02/26/2020

AMSAT has commented[1] on the FCC Notice of Proposed Rulemaking (NPRM[2]) in WT Docket 19-348 that proposes to delete the 3.3 - 3.5 GHz (9 centimeter) amateur band and relocate incumbent non-federal operations. The band includes the 3.40 - 3.41 GHz Amateur Satellite service allocation. In its remarks, AMSAT said it opposes deletion of the allocation and stressed the necessity of having adequate microwave spectrum available for future amateur satellite projects, including AMSAT's GOLF program and the Lunar Gateway. AMSAT acknowledged that the 3.4 GHz Amateur Satellite service allocation is not currently used by any amateur satellites and that it is unsuitable for worldwide communication becauseÿit is not available in ITU Region 1. AMSAT said a number of potential future uses for the band remain, however, as worldwide usage of other available allocations increases.

"These potential uses include a future amateur satellite in geostationary orbit above the Americas," AMSAT said, explaining that the segment could support uplink or downlink frequencies for such a spacecraft without potential interference to worldwide activities involving space stations in high-earth or lunar orbit. The most-desirable allocations for use as uplinks are between 2.4 GHz and 5.67 GHz - 80 megahertz in all, AMSAT told the FCC. "As many of the proposed uses include amateur television and high-speed data transmission with satellites in high-earth orbit or lunar orbit, these allocations may quickly become inadequate," AMSAT said.

AMSAT said the 3.40 - 3.41 GHz allocation could be utilized as a command channel or secondary data downlink for AMSAT ground stations in ITU Region 2, without interfering with the primary communications on the other allocations or other satellites utilizing those segments," AMSAT told the FCC.

AMSAT told the FCC the 3.40 - 3.41 GHz allocation could be utilized as a command channel or secondary data downlink for AMSAT ground stations in ITU Region 2 without interfering with the primary communications on the other allocations or other satellites utilizing those segments.

AMSAT said several non-amateur satellites use the broader 3.3 - 3.5 GHz amateur allocation, which also sees wide use for amateur radio mesh networking, EME communications, and contesting.

"The amateur satellite service continues to provide immense value to the growing field of small satellites," AMSAT concluded. "Experiments conducted by amateur satellites...continue to inform the development of the commercial small satellite industry. Additionally, student participation in amateur satellite projects provides both inspiration for young men and women to pursue careers in the commercial satellite industry and practical experience for those careers.

"A strong and robust amateur satellite service will continue to benefit the public interest and inspire future developments in satellite technology," AMSAT said. "Continued progress in achieving these goals requires adequate spectrum, especially in suitable microwave bands." - Thanks to AMSAT News Service via AMSAT Executive Vice President Paul Stoetzer, N8HM

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[1] https://www.amsat.org/wordpress/wp-content/uploads/2020/02/Comments-of-Radio-Amateur-Satellite-Corporation-WT-Docket-No-19-348.pdf
[2] https://docs.fcc.gov/public/attachments/FCC-19-130A1.pdf

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