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 Previous: The K7VVV Solar Update |  Next: AO-40 Attitude Control System Appears Functional |
NEWINGTON, CT, Aug 17, 2001--The ARRL has called on the FCC to put an end to commercial encroachments on Amateur Service allocations in the 2.3 and 2.4 GHz bands. In reply comments filed August 16 on a petition by AeroAstro to share co-primary status with the Amateur Service at 2300 to 2305 MHz, the ARRL reiterated its stance that the company's petition represents "a Trojan Horse" and that there is no way that Amateur Radio and AeroAstro's position-monitoring system could share the same spectrum.
"It is time for the Commission to stop those encroachments, because they have gone too far already," the ARRL said.
The League said AeroAstro's petition for a commercial Miscellaneous Wireless Communication Service allocation at 2300 to 2305 MHz not only would impose "preclusive operating conditions" on hams but represents "yet another in the continuing series of encroachments" into amateur allocations between 2300 and 2450 MHz. The ARRL asserted that while AeroAstro has repeated "its mantra" that hams and low-power commercial operations can share the band on a co-primary basis without interfering with each other, "the mantra is bereft of technical support." For its part, the ARRL attached an interference study prepared by the ARRL Lab that predicts "intolerable" interference, especially to weak signals.
ARRL has petitioned to elevate the Amateur Service from secondary to primary status on the band and requested that no commercial operations be introduced. AeroAstro seeks co-primary status with the Amateur Service to accommodate its Satellite Enabled Notification System (SENS) position-monitoring system under MWCS rules.
The FCC put both petitions on public notice last month, and both parties filed comments earlier this month. There is no primary occupant at 2300-2305 MHz.
"There is no dispute that the segment near 2304 MHz is uniquely suited to amateur weak-signal communications, and the remainder of that segment is used and useful for other types of amateur communication," the ARRL said in its reply comments.
AeroAstro has claimed that its 1 W spread-spectrum SENS uplinks and Amateur Radio can share the 5 MHz of spectrum and still protect the nearby NASA Deep Space Network. While contending that it "does not seek to cut back current Amateur operations in the band," AeroAstro also called on the FCC to limit amateurs to 100 W output and antennas with a beamwidth no greater than 5 degrees for "narrowbeam" operation such as Earth-Moon-Earth communication. For other operation, AeroAstro wants the FCC to limit amateurs to 25 W EIRP. The ARRL has called the recommendations "Draconian" and "totally unacceptable."
The ARRL has contended that AeroAstro should wait until the FCC finalizes another proceeding, ET Docket 00-221, that would make spectrum at 1670 to 1675 and 2385 to 2390 MHz available for the MWCS system it proposes. In its reply comments this week, the ARRL said the AeroAstro MWCS proposal and an earlier one from MicroTrax for "intrusive or exclusive commercial use" of 2300 to 2305 MHz were "gluttonous, to say the least," given existing and soon-to-be-available MWCS allocations.
The ARRL asked the FCC to dismiss the AeroAstro petition as defective and to grant the League's petition for primary amateur status at 2300 to 2305 MHz.
A copy of ARRL's reply comments in the proceedings, RM-10165 and RM-10166, are available on the ARRL Web site.
| Previous: The K7VVV Solar Update | Next: AO-40 Attitude Control System Appears Functional |
