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ARRL General Bulletin ARLB040 (1998)

ARLB040 ARRL files against LMCC

ARRL Bulletin 40  ARLB040
From ARRL Headquarters
Newington CT  June 2, 1998
To all radio amateurs

ARLB040 ARRL files against LMCC

The ARRL has asked the FCC to immediately dismiss efforts by the
Land Mobile Communications Council to gain primary access to 420 to
430 MHz and 440 to 450 MHz as well as other UHF allocations.  The
LMCC recently petitioned the FCC to reallocate the two 70-cm
segments from the federal government to the Private Mobile Radio
Service.  Amateur Radio enjoys the use of 420 to 450 MHz on a
secondary basis.  In comments filed on RM-9267, the League said the
LMCC proposed the switch ''without establishing technical
compatibility between PMRS operation and incumbent radio services in
any of the bands sought.''

The League said that existing federal government use of the spectrum
precludes PMRS operation at 420 to 450 MHz.  According to the ARRL,
the petition fails to demonstrate any basis to withdraw the two band
segments from federal use nor any compatibility between PMRS
operation and either federal government or Amateur use.  In
addition, the League said, the petition fails to justify displacing
established amateur operations.  The League pointed out that the
amateur community uses the band for public service and public safety
functions and that hams have ''substantial personal investment'' in
equipment that's in regular use there.  The ARRL urged the
Commission to throw out this portion of the LMCC petition ''without
further consideration.''

The League backed up its arguments by citing documents from the
National Telecommunications and Information Administration (NTIA),
which manages federal spectrum.  ''NTIA has made it quite clear that
there is no possibility of additional sharing of the 420-450 MHz
band, and the unique relationship between Federal radiolocation uses
and the Amateur Service cannot be duplicated by PMRS users,'' the
ARRL said.

The ARRL said that the LMCC petition was premature because it did
not take adequate account of the benefits of spectrum refarming
already initiated.  The League said PMRS users should adopt already
available spectrum-efficient technologies to maximize their use of
existing allocations before seeking additional spectrum at the
expense of other users.  The League also said that PMRS users should
look into using the Commercial Radio Mobile Service (CMRS).  A copy
of the League's comments is available at


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