Hello All,What I find extremely unacceptable is that the only strategy advanced is one where we seem to be pursuing is the measured withdrawal from this band. When we finally loose, that option would be a last move.There should be a filing and statement of strong objection with the of points similar to those that Rod has posted. Our voice of opposition should be prepared go beyond the Commission. Attempting to use contest logs will not present the strongest tenant for the public good available through continued access to some portion of 3.3 Ghz by amateur radio.We will not be successful trying to make our case on the objective numbers of bandwidth occupancy. But we must make a strong objection to loss of any access by the only non-commercial use that emphasizes education, experimentation and public service.The League shouldn't be seen as just laying down.... if we don't strongly oppose this we are not fulfilling our obligations.There needs to be activism beyond seeking access to the band until the successful bidder takes “possession”. Other areas on the globe have been successful with at least some access to the 3.3 GHz spectrum on frequencies best characterized as guard bands. That seems to be an achievable minimum, but not the goal.I am asking my colleagues if we would be ready to go to Congress to prevent the total loss of access to 3 GHz ?Thank You73, Kermit W9XA
Sent from Yahoo Mail for iPhoneOn Thursday, September 10, 2020, 17:39, Kermit Carlson via arrl-odv <arrl-odv@reflector.arrl.org> wrote:
Ria,I doubt that the fact my best DX in the past UHF and above Contest on 3.3 GHz was 350 km with 50 watts, would hold any sway with the Commission. What would work against us is that there would only be 5 stations active for the contest on 3.3 GHz within 150 km of a city the size of Chicago, and the fact that number is half of the stations equipped for the band in that same area.73, Kermit W9XA
Sent from Yahoo Mail for iPhoneOn Thursday, September 10, 2020, 16:43, rjairam@gmail.com <rjairam@gmail.com> wrote:
A member has suggested to me that we pull logs from LoTW and do some statistical analysis. Not necessarily for number of contacts but things like distance where we can show the band being used for experimental purposes.IMO it is quality, not quantity we are looking for.I’ve also reached out to Gordon Beattie (W2TTT) and Randy WU2S to see if they have anything as they are also AREDN folks. We may have this data already though.RiaN2RJOn Thu, Sep 10, 2020 at 12:53 PM Kermit Carlson via arrl-odv <arrl-odv@reflector.arrl.org> wrote:
Mark,Sorry to say that would not not helpful, that suggestion has beenconsidered previously...73, Kermit W9XA
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Perhaps we could have the contest branch pull up some data on recent contests and have that data available as well?Both 3.4 and 5 GHzJust a thought.Mark, HDXOn Thu, Sep 10, 2020 at 6:41 AM Rod Blocksome <rod.blocksome@gmail.com> wrote:David and ODV,I too echo Kermit's sentiments on retaining at least a small slice of bandwidth at or near 3400 MHz.There are numerous amateurs in the US engaged in technical and scientific pursuits on our microwavebands using the so-called "weak signal modes" e.g. CW, SSB, and WSJT-X digital. This technical pursuit by those amateurs, though frequently not publicised, directlyaddresses four of the five FCC stated reasons for the existence of the amateur radio service - namely (in bold):I too am active on 3456.100 MHz with 40 watts on CW & SSB as are four other amateurs in the Cedar Rapids, IA area.(a) Recognition and enhancement of the value of the amateur service to the public as a voluntary noncommercial communication service, particularly with respect to providing emergency communications.(b) Continuation and extension of the amateur's proven ability to contribute to the advancement of the radio art.(c) Encouragement and improvement of the amateur service through rules which provide for advancing skills in both the communication and technical phases of the art.(d) Expansion of the existing reservoir within the amateur radio service of trained operators, technicians, and electronics experts.(e) Continuation and extension of the amateur's unique ability to enhance international goodwill.73's, Rod, K0DASOn Thu, Sep 10, 2020 at 8:09 AM Kermit Carlson via arrl-odv <arrl-odv@reflector.arrl.org> wrote:
Hello David,Thank you for that (unfortunate) report of our situation. I do want to makethe Board aware that although the use of 3.3 and 5.7 GHz has a great amountof use for data transmission in support of emergency communications there isa large amount of interest in maintaining at least small slivers for use by theweak signal and EME community. As a matter of disclosure, I am activeand equipped for weak-signal operation on 3456 MHz.IARU Region one has provided a smaller area at 3400-3410 MHz or3395
to 3405 MHz. 3400.1 MHz has become the EME calling frequency.Although loosing access to the full bands is a terrible option, it does appearthat we could at least maintain access to a smaller "guard band".I have heard the request from many of the weak signal operators that if nothingelse try to obtain a sliver of spectrum near 3 GHz if at all possible.Is there any additional information available today ?73, Kermit W9XA
On Tuesday, September 8, 2020, 9:30:23 PM CDT, david davidsiddall-law. com <david@davidsiddall-law.com> wrote:
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I wanted to let you know that in the wake of last month’s Defense Department/FCC agreement on reallocating 3450-3550 GHz, the FCC has scheduled for Sept. 30 action on the
3.3-3.55 GHz proceeding generally. The Chairman spoke about it today. The draft provides for removing all secondary as well as primary operation – including radio amateur uses. What I do not know is the Commission’s proposed timeframe for the removal –
immediate, when re-licensed, or what. Tomorrow I will learn that and any other pertinent details. We will, of course, reinvigorate work to oppose this.
The one publication that all FCC staffers and Commissioners receive and at least peruse is Communications Daily. I’ve discussed this issue with the editor there and he
covered our earlier filing. Tomorrow’s edition prominently notes on page 1 that “Amateur operators raised objections, saying they need the broader 3.3-3.55 GHz for data networks in support of emergency communications”. And indeed, emergency communications
use will be our take-off point in opposing this over the next week.
The FCC Chairman also described the proposal in a blog posting, the pertinent part of which is extracted below FYI.
The current FCC seems to have a real problem understanding the concept of secondary use and wasting spectrum by letting it lie idle. We’ll see what we can do. There are
5 votes for this, Dems and Reps., but that doesn’t mean some change can’t be made.
I am making inquiries, but if you have concrete information on use of 3.4 GHz amateur systems related to the forest fires in CA and/or
hurricanes in the gulf coast this year, please send it to me ASAP, so that I am sure to have it, thanks. A one-or-two sentence description of what the use was and confirmed use in this band is all that is necessary for each use.
FCC CHAIRMAN PAI BLOG EXCERPT
Today, 750 megahertz of spectrum in the 2.9–3.65 GHz band is allocated for high-powered defense radar systems. But the average measured occupancy (or use) of the 3450–3550 MHz segment of this
band is less than 1% at sites without a significant military presence, according to a study recently completed by the Department of Commerce’s National Telecommunications and Information Administration. In the MOBILE
NOW Act, Congress required that the 3100–3550 MHz band be studied for the feasibility of commercial use. In 2018, NTIA identified the 3.45–3.55 GHz band for potential repurposing to spur commercial wireless innovation. And most recently, the White
House and the Department of Defense announced last month that this 100 megahertz of contiguous mid-band spectrum should be made available for 5G as quickly as possible.
Fortunately, the FCC was already working on ways to maximize use of this spectrum, so we are able to move quickly to do our part to repurpose this mid-band spectrum for commercial 5G. Building
on a rulemaking launched in 2019, I have circulated to my fellow commissioners a Report and Order to remove the secondary, non-federal allocations from the 3.3–3.55 GHz band. This is a critical first step toward making the 3.45–3.55 GHz band available for
innovative commercial operations while accommodating limited remaining operations by federal incumbents — one we’ll vote on at our next meeting on September 30. We will also vote on seeking comment on further changes to the band to enable future commercial
use, such as reallocating the 3.45–3.55 GHz band on a co-primary basis for non-federal fixed and mobile (except aeronautical mobile) services, rules for limited future federal incumbent use of the band, and licensing, operating, and technical rules for commercial
operations. Along with the upcoming December C-band auction of 280 megahertz of mid-band spectrum for 5G and the recently completed auction of 70 megahertz of licensed spectrum in the 3.5 GHz band, this new proposal would put the Commission on track to have
a 530-megahertz swath (from 3.45 to 3.98 GHz) of mid-band spectrum available for 5G. That’s 5G
FAST, to coin a phrase.
Dave
David R. Siddall
Managing Partner
DS Law, PLLC
direct: +1 202 559 4690
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