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ARRL General Bulletin ARLB015 (2015)

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ARLB015 ARRL to FCC: Amateurs and Vehicular Radars Can Play Nicely
Together on 77-81 GHz

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ARRL Bulletin 15  ARLB015
From ARRL Headquarters  
Newington CT  April 7, 2015
To all radio amateurs 

SB QST ARL ARLB015
ARLB015 ARRL to FCC: Amateurs and Vehicular Radars Can Play Nicely
Together on 77-81 GHz

In comments filed on April 6 in response to a February FCC Notice of
Proposed Rulemaking and Reconsideration Order (NPRM&RO) in ET Docket
15-26, the ARRL has told the Commission that it should make no
change in the Amateur Radio allocation at 76-81 GHz and impose no
additional regulatory constraints on Amateur or Amateur-Satellite
uses of the band. The League said the FCC should proceed with
authorizing short-range radar (SRR) systems for automotive
applications in the band under Part 15 rules, and that such
applications are compatible with amateur operations in the band.
The NPRM&RO can be found on the web in PDF format at,
https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-16A1.pdf
.

In its NPRM&RO, the FCC solicited comment on issues involving
expanded use of various radar applications in the 76-81 GHz band,
which Amateur Radio shares with other services. The band 77.5-78 GHz
is allocated to the Amateur and Amateur Satellite services on a
primary basis, and to the Radio Astronomy and Space Research
services on a secondary basis. The NPRM&RO was in response to a 2012
Petition for Rulemaking (RM-11666) by Robert Bosch LLC and to two
petitions for reconsideration of a 2012 Report and Order (R&O)
addressing vehicular radar systems in the 76-77 GHz band. ET 15-26
incorporated earlier proceedings.  The R&O can be found on the web
at, http://www.fcc.gov/document/toyotaera-76-77-ghz-band .

In its comments, the ARRL suggested that the FCC overreached in
proposing unjustifiable changes at 77-81 GHz on its own initiative.

"There is not, anywhere in the four corners of the Bosch Petition
for Rule Making or in any comments that have been filed thus far in
response to RM-11666, any suggestion that there is any
incompatibility between Amateur Radio operation and automotive
radars," the ARRL said. "Quite the contrary." The League said a
credible, current ITU study has "definitively established"
compatibility between short-range automotive radars and Amateur
Radio.

The ARRL said Bosch's filing of its Petition followed "extensive
discussions and technical evaluations between ARRL and Bosch" that
making spectrum at 77-81 GHz available for automotive radars "would
have no significant impact on the Amateur Radio Service." Bosch, the
League pointed out, "did not propose a domestic spectrum allocation
for vehicular radar devices and systems," just modification of the
FCC Part 15 rules to permit vehicular radars at 78-81 GHz on the
same basis that these radars now operate in the US at 76-77 GHz - on
a non-allocated, non-interference basis.

The ARRL said that no changes are necessary in the Amateur Radio
domestic primary allocation at 77.5-78 GHz or in the secondary
amateur allocation at 77-77.5 GHz or 78-81 GHz to accommodate
automotive radar systems at 77-81 GHz. "Nor are any additional Part
97 rules necessary to accommodate compatible sharing of that band
between radio amateurs and automotive radar systems," the League
added. "Indeed, that is the position of the United States in
anticipation of consideration of WRC-15 agenda item 1.18 later this
year."

The League characterized as "both premature and poor spectrum
management" the FCC's proposal to unilaterally permit unspecified
fixed radar systems throughout the 76-81 GHz band "without the
benefit of any completed, definitive studies relative to the
compatibility of fixed radar systems with automotive radar,
radioastronomy and/or Amateur Radio in this band."

Any consideration of fixed radars at 77-81 GHz, the League said,
"should await the completion of conclusive, refereed compatibility
studies that credibly establish compatibility with incumbent
services."

The ARRL said should there be any "unjustified displacement" of the
Amateur or Amateur-Satellite services from any portion of the 76-81
GHz band, the FCC should allocate "equivalent spectrum" for those
services. As possibilities, the League suggested the bands 75.5-76
GHz and 81-81.5 GHz.

The deadline for reply comments - ie, comments on filed comments -
in this proceeding is April 20. The ARRL plans to file reply
comments.
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