AG26
QST de W1AW  
ARRL Bulletin 26  ARLB026
>From ARRL Headquarters  
Newington CT  September 28, 2020
To all radio amateurs 

SB QST ARL ARLB026
ARLB026 ARRL Seeks Changes in FCC Proposal to Delete 3.4 GHz Amateur
Band

ARRL met via telephone with FCC staff members this week to emphasize
its opposition to the FCC Notice of Proposed Rulemaking (NPRM) in
Docket 19-348 to delete amateur radio from the 3.3 - 3.5 GHz band.

The FCC will take final action in the proceeding when it meets on
September 30.

The NPRM can be found online in PDF format at, 
https://ecfsapi.fcc.gov/file/121661888341/FCC-19-130A1.pdf .

In comments filed earlier this year, ARRL urged that the secondary
status for amateur radio in the band be continued. In a series of
meetings with Commissioner legal advisors and staff members, ARRL
explained how continued secondary use by radio amateurs will not
impair or devalue use of this spectrum by future primary licensees,
including those intending to provide 5G or other services. ARRL also
stressed the various public-benefit uses of the spectrum by
amateurs, including ongoing use of television and mesh networks on
the west coast of the US as part of efforts to contain wildfires.

With regard to interference potential, ARRL stated that amateur
radio operators using these bands are technically proficient and
have a long history of sharing with primary users in this and other
bands without causing interference.

FCC staff expressed concern that because amateur operations in the
band are less clearly defined than those of other services also
operating on a non-interference in the band, they would be difficult
to locate should interference occur. ARRL Washington Counsel David
Siddall, K3ZJ, noted that Section 97.303(g), an existing amateur
rule, could be amended or used to craft a notification requirement,
if the FCC concluded that relying on other methods would be
insufficient.

The FCC participants indicated that such a requirement, in place of
deleting the secondary allocation, would be given serious
consideration. (Section 97.303(g) contains specific
frequency-sharing requirements for the 2200- and 630-meter amateur
bands.)

Siddall also pointed out that the Amateur Television Network (ATN)
filed an email with the Commission that included a letter from the
California Governor's Office of Emergency Services (Cal OES)
describing amateur radio's contributions, specifically calling out
the need for 3.4 GHz access and explaining why other bands are not
sufficient.

ARRL also argued that, in any event, continued operation in the band
should be permitted until and unless an actual potential for
interference exists in a specific geographic area. ARRL said the FCC
should not intentionally leave spectrum capacity unused during a
build-out period that the Commission's own proposal indicates will
last for at least 12 years in some areas.

The record in the proceeding is now closed. Please be reminded that
there can be no calls, emails, or filings to the FCC with regard to
the issues under consideration until a final FCC Report and Order
and Further Notice of Proposed Rulemaking is released.

Release is currently expected to be within a few days after the
Commission's September 30 meeting. At that time, ARRL will evaluate
the impact on amateur radio of the Commission's decisions and
consider what further action, if any, may be merited.