12/17/2019

At its December 12 meeting, the FCC formally adopted a Notice of Proposed Rulemaking (NPRM[1]) in WT Docket 19-348 and invited comments on its plan to remove "existing non-federal secondary radiolocation and amateur allocations" in the 3.3 - 3.55 GHz band and relocate incumbent non-federal operations. The FCC said it's seeking comment on appropriate "transition mechanisms" to make that happen. ARRL has indicated that it will file comments in opposition to the proposal. The amateur 9-meter allocation is 3.3 - 3.5 GHz. The NPRM comes in response to the MOBILE NOW [Making Opportunities for Broadband Investment and Limiting Excessive and Needless Obstacles to Wireless] Act, approved by the 115th Congress to make available new spectrum for mobile and fixed wireless broadband use.

"By proposing to delete the existing non-federal secondary allocations from the 3.3 - 3.55 GHz band, we are taking an important initial step towards satisfying Congress's directives and making as much as 250 megahertz of spectrum potentially available for advanced wireless services, including 5G," the FCC said in the Introduction to its NPRM.

Currently, the entire 3.1 - 3.55 GHz band is allocated for both federal and non-federal radiolocation services, with non-federal users operating on a secondary basis to federal radiolocation services, which have a primary allocation, the NPRM explains.

The FCC said it is seeking comment on relocating non-federal licensees to another band. With respect to amateur operations, the FCC invited comments on whether sufficient amateur spectrum exists in other bands that can support the operations currently conducted at 3.3 - 3.5 GHz. The 3.40 - 3.41 GHz segment is earmarked 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 said. If non-federal licensees are relocated to 3.1 - 3.3 GHz band, the FCC proposes that they continue to operate on a secondary basis to federal operations, consistent with current band allocations.

Some comments began to arrive before the FCC formally adopted the NPRM, as it points out in a footnote. Kevin Milner, KD0MA, the secretary/treasurer of the Ski Country Amateur Radio Club in Colorado, has argued that the club's equipment cannot be re-channeled below 3.4 GHz, and the club is seeking relocation costs. Devin Ulibarri, W7ND, told the FCC that amateur networks in the current band cannot move easily into other amateur allocations because there is no readily available commercial equipment to support the bandwidth, the FCC recounted.

In the event the proposed amendments are adopted, the FCC "seeks comment on relocation options and on transition and protection mechanisms for incumbent non-federal operations."

Also at its December 12 meeting, the FCC considered 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, which 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. Although no changes have been proposed to the amateur allocation, an increase in primary use is anticipated, which could restrict secondary amateur use.

The Amateur Radio Emergency Data Network (AREDN[2]) has offered its voice[3] in challenging the FCC proposals on the two bands, saying their adoption would "eliminate our use of the most-effective resource hams have to build its networks."

"The AREDN Project is able to leverage low-cost commercial devices solely because they are designed to operate on adjacent allocations," AREDN said on its website. "Moving to other allocations would be difficult if not impossible without a complete redesign, manufacture, purchase, and installation of new custom amateur hardware and software..., raising the price out of reach for the typical ham."

Interested parties may file short comments on WT Docket 19-348 via the FCC's Electronic Comment Filing Service (Express)[4]. Visit the FCC "How to Comment on FCC Proceedings[5]" page for information on filing extended comments.


[1] https://docs.fcc.gov/public/attachments/FCC-19-130A1.pdf
[2] https://www.arednmesh.org/
[3] https://www.arednmesh.org/content/call-action-defense-part-97-allocations [4] https://www.fcc.gov/ecfs/filings/express
[5] https://www.fcc.gov/consumers/guides/how-comment

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