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 microwave

bands 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, directly

addresses four of the five FCC stated reasons for the existence of the amateur radio service - namely (in bold):

(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.

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.

73's, Rod, K0DAS

On 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 make

the Board aware that although the use of 3.3 and 5.7 GHz has a great amount

of use for data transmission in support of emergency communications there is

a large amount of interest in maintaining at least small slivers for use by the

weak signal and EME community.   As a matter of disclosure, I am active

and equipped for weak-signal operation on 3456 MHz.

        IARU Region one has provided a smaller area at 3400-3410 MHz or

3395 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 appear

that 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 nothing

else 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:

 

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

1629 K St. NW, Ste 300

Washington, DC 20006

direct: +1 202 559 4690

 

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