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NEWINGTON, CT, Oct 24, 2001--The ARRL this week urged the FCC "in the strongest possible terms" to make no commercial allocations in the Amateur Service 2390 to 2400 MHz primary allocation. The League tentatively suggested, however, that hams might be willing to share the band with compatible government services that are displaced to make room for advanced wireless systems.
"ARRL urges the Commission not to make any allocation of that band for advanced wireless services," the ARRL told the FCC. "Such are fundamentally incompatible with continued amateur access to the band."
The ARRL said the federal government "has historically been a compatible sharing partner" and that government uses would offer "the least disruptive opportunities for sharing" in the band. Such sharing, the League made clear, should happen only "if it is absolutely necessary to reaccommodate some displaced users" and would be "subject to compatibility studies."
The ARRL commented this week in four separate proceedings dealing with allocations for advanced and third-generation wireless systems, the mobile satellite service and the Unlicensed Personal Communications Service (U-PCS). The ARRL focused its remarks on ET Docket 00-258, which included 2390-2400 MHz as a candidate band for advanced wireless services.
The ARRL said that while it might not be opposed to reallocating "additional compatible users," it also asked the FCC to retain the non-government primary Amateur Service allocation at 2390-2400 MHz.
The ARRL said that commercial use of 2390-2400 MHz would preclude incumbent and future amateur operation, which, the League noted, has been growing over the past five years or so. The League also questioned the suitability of the 2390-2400 MHz band in the US for so-called third-generation cellular systems and called it "an unsuitable candidate for international roaming."
Commenting on the WINForum Petition for Rule Making (RM-9498) that seeks to modify technical rules for Part 15 U-PCS operation at 2390 to 2400 MHz, the ARRL reiterated its position of two years ago. The ARRL said it still opposed a power increase for asynchronous U-PCS devices in the band and said there can be no change in maximum power spectral density. "These two provisions are critical to the compatible sharing plan that resulted in ARRL support of the U-PCS authorization at 2390-2400 MHz," the ARRL said. While it does not oppose eliminating the "listen-before-transmit" protocol, the League said there is no justification to double permitted antenna gain, as requested, without a commensurate reduction of transmitting power. ARRL and Apple Computer negotiated the current sharing arrangement.
The ARRL's
comments took note of the fact that amateur allocations in the vicinity of 2
GHz "have been steadily eroded" through encroachment by other services. "Of the
original 150 MHz [once available to amateurs], the only primary amateur
allocation that is actually available for a variety of amateur uses is the 10
MHz at 2390-2400 MHz," the ARRL said.