AG10
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ARRL Bulletin 10  ARLB010
>From ARRL Headquarters  
Newington CT  May 9, 2018
To all radio amateurs 

SB QST ARL ARLB010
ARLB010 ARRL Asks FCC to Protect Amateur Radio Millimeter-Wave Bands

ARRL has asked the FCC to avoid authorizing developmental
technologies in two Amateur Radio bands above 95 GHz that some radio
amateurs may not be unaware of. The ARRL commented on May 2 in
response to a Notice of Proposed Rule Making and Order (NPRM&O) in
ET Docket 18-21, released in February. The so-called 'Spectrum
Horizons' proceeding seeks to make the bands above 95 GHz 'more
readily accessible for new innovative services and technologies.'

ARRL said that, while it agrees that 'regulatory flexibility is
justified' in the millimeter-wave bands above 95 GHz, due to the
extensive frequency re-use possibilities, the FCC ought to make two
primary Amateur/Amateur Radio Satellite bands in that part of the
spectrum unavailable for deployment of unlicensed Part 15 or Part 5
Experimental Spectrum Horizons devices. Amateur Radio has primary
allocation status in the bands 134 - 136 GHz and 248 - 250 GHz, both
shared with the Radio Astronomy Service, which is secondary.

The NPRM&O can be found on the web in PDF format at,
https://apps.fcc.gov/edocs_public/attachmatch/FCC-18-17A1.pdf
.

'The amateur allocations require protection against increases in the
noise floor due to aggregate radio frequency devices,' ARRL said.
'The bands are used ubiquitously and unpredictably, typically, but
not always, at high elevations for research and development purposes
and propagation studies, for terrestrial point-to-point, satellite,
and Earth-Moon-Earth communications experimentation.'

ARRL said it would oppose 'any proposal to permit unlicensed devices
or largely unregulated experimental operations' in the two primary
Amateur Radio allocations in the range of spectrum the FCC is
considering. 'It is critical to preserve for Amateur Radio
experimentation the current relatively quiet noise floor, and the
positive RF environment that now exists in those two relatively
small band segments,' ARRL told the FCC. The League's comments noted
that the secondary Radio Astronomy Service in those two bands also
requires a quiet RF environment.

In strongly urging that the FCC not permit unlicensed Part 15 in
either primary amateur band 'under any circumstances,' ARRL pointed
out that the FCC has no data concerning increases in the noise floor
from potentially large numbers of unlicensed Part 15 devices in
either band. Additionally, ARRL said, 'There is no compelling need
to include these two bands among those which might be made available
for unlicensed devices and systems in this proceeding.'

ARRL said it also would oppose the authorization of Spectrum
Horizons experimental authorizations in the two primary
Amateur/Amateur Satellite allocations, operating under a new subpart
for Spectrum Horizons Experimental Radio Licenses' in the spectrum
at issue.

ARRL said it would be difficult for such applicants to make an
accurate showing of non-interference in the two amateur allocations,
'due to the variety and itinerant nature of Amateur Radio
allocations.'

If the FCC should nonetheless decide to permit Spectrum Horizons
experimental authorization applicants to apply for 134 - 136 GHz and
248 - 250 GHz, however, ARRL said applicants should have to
'demonstrate convincingly' that no other suitable allocations are
available, and that they coordinate their operations with ARRL when
filing an application.

The omnibus NPRM&O includes consideration of a Petition for Rule
Making (RM-11795) from Missouri radio amateur James Whedbee, N0ECN.
He asked the FCC to adopt rules to permit the operation of
unlicensed devices in the 95 - 1000 GHz range, by and large applying
the same technical rules to those unlicensed operations as currently
apply in the 57 - 71 GHz band.

'Overall, the Commission is on the right track in this proceeding,'
ARRL allowed. Opening the millimeter-wave bands to expanded
unlicensed operation is not unreasonable. 'Some, but not all, of the
bands above 95 GHz can be removed from the Part 15 restricted band
list in Section 15.205(a) of the Commission's rules without
significant concern,' ARRL concluded. 'However, the Amateur Radio
primary allocations at 134 - 136 GHz and 248 - 250 GHz, which are
shared with radio astronomy, should be unavailable for either Part
15 operation or for other commercial development.'