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ARRL Asks FCC to Keep 2300 MHz Proceeding Open

07/22/2011

In June, the FCC released a Public Notice that sought comments on whether or not it should terminate approximately 800 docketed proceedings in the Wireless Telecommunications Bureau (WTB), the International Bureau (IB), the Office of Engineering and Technology (OET) and the Enforcement Bureau (EB). Some of the proceedings set for possible termination affect the Amateur Radio Service. On July 20, the ARRL filed comments with the FCC on this matter, explaining that it has no objection to the termination of the proceedings in the Public Notice, save for one item. “With respect to the Office of Engineering and Technology dockets slated for termination,” the ARRL stated in its comments, “there is one Amateur Radio-related proceeding that, in the ARRL’s view, should not be terminated, but retained in open status.

Earlier this year, the FCC adopted procedural rules specifying that proceedings where pending petitions addressing the merits should not be terminated without the consent of the parties involved. "With this in mind, the ARRL does not consent to the termination of the proceeding initiated by its May 2001 rulemaking petition RM-10165, Amendment of Parts 2 and 97 of the Commission’s Rules Regarding the 2300-2305 MHz Band," the League stated in its comments. In this Petition, the ARRL requested that the FCC change the Amateur Radio Service’s allocation in that band from Secondary to Primary.

The ARRL’s Petition was filed May 7, 2001 and it was placed on Public Notice on July 2, 2001. In October 2002, the OET issued an Order dismissing this and two other petitions pertaining to the 2300-2305 MHz band. The ARRL noted in its comments that “that Order did not finally resolve the issue of the allocation status of the Amateur Service in the 2300-2305 MHz band, or the ARRL’s request for a Primary allocation. Rather, the Commission merely postponed a decision with respect to the allocation status of that band until some unspecified future time.”

The Commission stated in its October 2002 Order that as it was dismissing the Petitions for Rulemaking from Microtrax and AeroAstro for access to this spectrum, “amateur operators’ weak signal communications in the 2300-2305 MHz band will be protected if the amateur allocation remains secondary. This band will remain in the Commission’s reserve, and the status quo in the band will be maintained until the Commission reevaluates the spectrum reserve at some future date. At that time the Commission can address any modifications to the allocation status for the amateur service that may be appropriate. Accordingly, we are also dismissing the ARRL Petition for a primary allocation to the amateur service in the 2300-2305 MHz band.”

According to the ARRL, the status of the Amateur Radio allocation at 2300-2305 MHz is of current relevance because of actions taken by the Commission with respect to an adjacent band at 2305-2320 MHz and because of other unrelated proposals for the use of the 2300-2305 MHz band. “In a Report and Order and Second Report and Order, the FCC amended certain technical rules governing the Wireless Communications Service (WCS) in the 2305-2320 MHz band, so as to delete the effective limitations on WCS terrestrial operations to fixed services and to enable licensees to provide mobile broadband services in 25 megahertz of the WCS band, the ARRL said in its comments. “In so doing, the Commission indicated that out-of- band emissions from WCS, when expanded to permit mobile broadband and portable devices at up to 250 mW EIRP, will have an effect on amateur operations in the 2300-2305 MHz band.”

The FCC, in the Report and Order and Second Report and Order, explained that “we note that some amateur stations operating around 2304 MHz may experience an increased antenna noise temperature caused by the implementation of mobile WCS operations, and will have to tolerate this change in the RF environment. Due to the technical flexibility allowed to amateur stations in Part 97 of our rules, however, we believe that operators of these stations may be able to offset or mitigate the effects of this change by relocating or redirecting their antennas, or by making other permitted technical adjustments.”

The ARRL explained that this conclusion -- and the issue of interference to Amateur Radio operation at 2300-2305 MHz -- has been challenged by ARRL in a pending Petition for Clarification or Partial Reconsideration filed September 1, 2010.The International Radio Regulations and Section 2.102(f) of the Commission’s rules make no distinction between secondary and primary services in their entitlement to protection from out-of-band and spurious emissions from a service operating in an adjacent band,” the ARRL stated. “Secondary services are entitled to such protection irrespective of the allocation status of the source of the interference in the adjacent band. Furthermore, in the currently open ET Docket 08-59, some comments counterproposed the use of the 2300-2305 MHz band for Medical Body Area Networks in lieu of the 2360-2400 MHz band.”

Due to the current relevance of the allocation status (and interference protection status) of the Amateur Service at 2300-2305 MHz, and considering that in October 2002, the FCC did not make any decision with respect to the allocation status of that band and postponed it to some unspecified future time, the ARRL maintains that “the RM-10165 proceeding should remain open and pending, and that the Commission should revisit the allocation status of the Amateur Radio Service at 2300-2305 MHz, and the ARRL’s justifications offered for a change from Secondary to Primary status in that band now.”



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