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ARRL General Bulletin ARLB018 (2014)

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ARLB018 ARRL Again Asks FCC to Elevate Amateur Service 2300-2305 MHz
Allocation to Primary

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ARRL Bulletin 18  ARLB018
From ARRL Headquarters  
Newington CT  October 1, 2014
To all radio amateurs 

SB QST ARL ARLB018
ARLB018 ARRL Again Asks FCC to Elevate Amateur Service 2300-2305 MHz
Allocation to Primary

In comments filed in response to an AT&T Mobility Petition for Rule
Making seeking a new air-to-ground communications system on 2.3 GHz
Wireless Communications Service (WCS) spectrum, the ARRL has once
again asked the FCC to elevate the Amateur Service allocation at
2300 to 2305 MHz from secondary to primary. The Petition (RM-11731)
asked the Commission to authorize an LTE-based in-flight
connectivity service in the WCS "C" and "D" blocks (2305-2315 MHz
and 2350-2360 MHz, respectively) for airlines and airline
passengers. AT&T has asserted that restrictions on out-of-band
emission and power limits to protect adjacent-band users make the
use of the C and D blocks problematic. The wireless provider asked
the FCC for rule changes to permit deployment of its service "using
currently fallow spectrum" while also "preserving adequate
interference protection to users of adjacent bands."

"Notwithstanding this broad and nebulous claim, there is no showing
anywhere in the four corners of the Petition that the proposed rule
changes would permit any continued Amateur Radio operations on a
secondary basis in the shared A block (2305-2310 MHz)," the ARRL
commented on September 22. More to the point, the League said, there
is no showing in the Petition that Amateur Radio operations in the
adjacent 2300-2350 MHz band would be protected from increased
out-of-band emissions, if the FCC were to implement the changes
requested.

The League asserted in its comments that the FCC has, to date,
"failed to protect Amateur Radio operations at 2300-2305 MHz from
WCS out-of-band emissions." The ARRL said the band is "regularly and
substantially utilized by radio amateurs" for weak-signal,
long-distance communication and, only by circumstances - a lack of a
primary occupant - has it been able to enjoy that segment as a de
facto primary user.

"The Commission's rules are quite clear that WCS licensees enjoy no
entitlement to disrupt adjacent-band radio service operations," the
ARRL commented. But, the League pointed out, previous FCC actions to
expand mobile broadband devices left 2300-2305 MHz vulnerable to
increased out-of-band interference that would be difficult or
impossible to mitigate. The ARRL said amateur stations operating in
the 2300-2305 MHz band would be unable to avoid interference from AT
and T Mobility's proposed system, and that the FCC has refused to
clarify the obligation of WCS mobile providers to avoid interference
to Amateur Radio operations there.

The ARRL objected to what it called the FCC's "practice of making
allocation decisions which place incompatible uses in close
proximity to amateur stations and then place on the amateur
licensees the burden of avoiding the interference."

"It is obvious that the result of the AT&T Petition will be a
virtual preclusion of amateur access to the 2305-2310 MHz segment,"
the ARRL's comments continued. "A ubiquitous air-to-ground system
which operates at and above 2305 MHz will clearly render the
secondary allocation status of that segment a virtual nullity."

The ARRL asked the FCC to recognize Amateur Radio's "de facto
primary status" at 2300-2305 MHz and to elevate that segment from
secondary to primary for amateurs. It further called on the
Commission to "clarify the obligation of WCS licensees in all
contexts to protect the adjacent-band Amateur Service operations at
2300-2305 MHz from harmful interference." Finally, the League
requested that AT&T provide "a complete technical compatibility
showing and interference analysis" that would demonstrate
compatibility between its proposed service and amateur operations at
2300-2305 MHz.
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