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 Previous: Donor Reception, Forums Highlight ARRL's 2002 Dayton Activities |  Next: Expedition 4 Crew Wraps Up Successful String of ARISS School QSOs |
NEWINGTON, CT, May 14, 2002--The ARRL has asked the FCC to pull the 2390-2400 MHz amateur band out of consideration as possible "replacement spectrum" for relocated 800-MHz Public Safety band users. But the ARRL did leave the FCC some wiggle room. Earlier this year, the FCC again targeted the primary Amateur Service microwave allocation for possible sharing or use by other radio services. A Notice of Proposed Rulemaking (WT Docket 02-55)--released in mid-March--invited comments on either sharing the band with displaced Public Safety services or moving amateurs elsewhere.
"The band is unavailable for relocation of Nextel or other CMRS services, and should not be under consideration in this proceeding," the ARRL told the FCC in comments filed May 6. The FCC had referred to 2390-2400 MHz as an "Unlicensed PCS Band," but, as the League reminded the Commission, "That band is allocated on a primary basis to the Amateur Service domestically."
In 1995, the FCC accepted a proposal negotiated by ARRL and Apple Computer that involved a compatible sharing proposal for 2390-2400 MHz. Under the plan, the band was allocated on a primary basis to the Amateur Service and made available for use by asynchronous unlicensed Personal Communications Service (UPCS) devices regulated under Part 15. In the current proceeding, the FCC also sought comments on whether existing UPCS operations could continue in the band or be forced to cease.
The FCC has said that increasing incidents of harmful interference to public safety systems in the 800-MHz band prompted the latest rulemaking proceeding, "Improving Public Safety Communications in the 800 MHz Band." Nextel and other incumbents already have forwarded plans to the FCC to restructure the 800 MHz band and move some occupants elsewhere.
The Commission said its discussion of 2390-2400 MHz and other segments in terms of replacement spectrum was intended to be "illustrative rather than exclusive" and that other bands "may also merit consideration."
Last summer, the FCC invited comments on proposals to reallocate some spectrum in the 2390 to 2400 MHz amateur segment--as well as in the non-amateur 1.9 and 2.1 GHz bands--for possible use by unspecified mobile and fixed services. The Commission has proposed 2390 to 2400 MHz and other bands to support the introduction of advanced wireless services, including so-called third-generation (3G) mobile systems.
In the earlier proceeding, the FCC also asked for comments on whether amateurs could share the band with government users. Should it reallocate 1755-1850 MHz--now occupied by federal government users--for advanced wireless services, the Commission has hinted that it might again consider lumping relocated federal government users with amateurs on 2390-2400 MHz.
The ARRL said it's not prepared to speculate on relocation spectrum for amateurs if the primary amateur allocation is modified in either proceeding and amateurs are displaced. The League suggested that "some reaccommodation" might be made if the FCC allocates 2300-2305 MHz to the Amateur Service on a primary basis.
"While that would be, at best, an incomplete solution for the Amateur Service, it might contribute to the availability of some portion of the 2390-2400 MHz band for displaced 800 MHz licensees," the ARRL said. The ARRL already has petitioned the FCC for primary status at 2300 to 2305 MHz. The petition faces competition from AeroAstro, which wants co-primary status with the Amateur Service for its commercial satellite-based location service.
The 1995 ARRL-Apple agreement for 2390-2400 MHz includes constraints on power spectral density and other parameters. "Those carefully crafted operating parameters are not duplicated by most other commercial services," the ARRL said in its comments, noting that other uses might not be compatible with amateur operation on the band. At about the same time it adopted the ARRL-Apple sharing arrangement, the FCC itself concluded that certain proposed wide-area, high-power fixed and mobile services would be incompatible with amateur use of the band.
In its comments, the ARRL asked the FCC whether the band at 2390-2400 MHz will be subject to sharing between amateurs and relocated 800-MHz services "and, if not, whether incumbent amateur operators could be relocated, and, if so, where."
"It is a simple matter to conclude that there is no compatibility between displaced 800 MHz incumbents and amateur licensees in this band," the ARRL said. "This conclusion was already reached," the League added, for the same reason that Amateur Radio cannot share the band with advanced wireless services, as earlier suggested.
"Sharing between the Amateur Service and commercial services, especially mobile commercial services, is extremely difficult generally," the ARRL said. It cited the shared frequencies within amateur bands, the essentially mobile or itinerant character of amateur operation, relatively high amateur transmitter power levels and extremely sensitive receivers as primary reasons.
The FCC recently proposed upgrading the adjacent Amateur Radio 2400-2402 MHz allocation from secondary to primary, mainly to protect satellite operations. The AO-40 satellite has been successfully using the band for downlink telemetry and transponder operation, and AMSAT plans a similar downlink for its next satellite project. The Amateur Service already is primary at 2402-2417 MHz. There's a secondary amateur allocation at 2417-2450 MHz.
The complete NPRM and a copy of ARRL's comments [PDF] are available via the FCC Web site. Some related notices and correspondence are available via the FCC's Electronic Comment Filing System. Click on "Search for Filed Comments" and enter "02-55" in the "Proceeding" field.
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