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ARRL Replies to Wireless Services Filing in 2304 MHz Band Interference Debate

10/29/2010

On October 28, 2010, the ARRL filed a Reply to a Wireless Services Opposition filing, the latest in an ongoing series of exchanges regarding the FCC’s proposal to allow mobile broadband services, in addition to fixed services, to operate in parts of the 2.3 GHz band. The Amateur Radio Service has a secondary allocation at 2300-2310 MHz.

Here is a brief recap of the previous actions that led to the ARRL’s latest filing:

May 20, 2010: The FCC adopted amendments to its rules for Wireless Communications Services (WCS) in the 2.3 GHz band to permit mobile broadband services, in addition to fixed services, in the 2305-2317.5 and 2347.5-2360 MHz bands.

September 1, 2010:Concerned with the potential for harmful interference to amateur operations at 2.3 GHz, the ARRL filed a Petition for Clarification or Partial Reconsideration with regard to one aspect of the new rules.

October 18, 2010: The WCS Coalition filed an Opposition to the ARRL Petition.

In its September 1 filing, the ARRL requested that the Commission affirm:

1) That the current out-of-band emission (OOBE) limits for WCS devices set forth at Section 27.53(a)(3) of the Commission’s rules continue to apply to mobile, portable and fixed facilities across the entirety of the 2300-2305 MHz band following the rule changes implemented in the FCC’s original Report and Order.

2) That Section 2.102(f) of the Commission’s rules applies to Wireless Communications Service (WCS) fixed and mobile operations, so that harmful interference that is caused to Amateur Radio Service operations in the 2300-2305 MHz band is to be remedied by WCS licensees.

If the Commission wasn’t able to take positive action on these requests, the ARRL asked that the R&O be reconsidered. Further background appears in the article reporting on the September 1 ARRL Petition.

In its October 18 Opposition to this filing, the WCS raised no objection to the first request but opposed the second. The WCS, in essence, claimed that because the Amateur Service is secondary at 2300-2305 MHz and they are primary above 2305 MHz, they are not obligated to protect the Amateur Service from harmful interference.

The ARRL Reply states in part:

“WCS licensees, under existing rules: (1) have no entitlement to cause interference to licensed radio services outside of the Part 27 allocations beginning above 2305 MHz; and (2) do in fact have an obligation pursuant to Section 2.102(f) of the Commission’s Rules [47 C.F.R. 2.102(f)] to protect Amateur station operation in the 2300-2305 MHz band from interference due to WCS transmissions above 2305 MHz. Section 2.102(f) states that “(t)he stations of a service shall use frequencies so separated from the limits of a band allocated to that service as not to cause harmful interference to allocated services in immediately adjoining frequency bands….

The 2305-2310 MHz segment is allocated to the WCS now on a primary basis and to the Amateur Service on a secondary basis. There is no doubt but that at 2305-2310 MHz, Amateur operations are secondary to WCS operations and are not protected from interference from WCS facilities. However, WCS has no allocation below 2305 MHz, and the Commission’s rules (and the domestic Table of Allocations, Section 2.106 of the Commission’s rules) are quite clear that WCS licensees enjoy no entitlement to disrupt adjacent band radio services, and never have.”

The ARRL Reply points out that Section 2.102(f) “is taken almost verbatim from the international Radio Regulations, and so could not have had the limited application that WCSC erroneously surmises that the Commission intended.”

ARRL General Counsel Chris Imlay, W3KD, commented: “We are helped by the FCC rule that specifically says what we urged the FCC to clarify. That rule comes from the international Radio Regulations.”



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