AG24
QST de W1AW  
ARRL Bulletin 24  ARLB024
>From ARRL Headquarters  
Newington CT  December 19, 2019
To all radio amateurs 

SB QST ARL ARLB024
ARLB024 FCC Formally Adopts Proposals to Remove Amateur 3-GHz Band,
Invites Comments

At its December 12 meeting, the FCC formally adopted a Notice of
Proposed Rulemaking (NPRM) 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-centimeter 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.

The NPRM can be found online in PDF format at,
https://docs.fcc.gov/public/attachments/FCC-19-130A1.pdf .

'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.

This NPRM can also be found online in PDF format at,
https://docs.fcc.gov/public/attachments/FCC-19-129A1.pdf .

The Amateur Radio Emergency Data Network (AREDN) has offered its
voice 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). Visit the FCC
'How to Comment on FCC Proceedings' page for information on filing
extended comments at,
https://www.fcc.gov/consumers/guides/how-comment .