[arrl-odv:23962] MITRE Corporation HF Experimental Authorization

Greetings. As most of you know, we (Dave Sumner, Brennan Price, Dan Henderson and I) continually monitor granted FCC experimental authorizations (EXPs) and special temporary authority grants (STAs) which include Amateur Radio allocations. Most of the STAs are for short term operations (less than 6 months' duration) and few are of any concern to us, but some are if they are fundamentally incompatible with ongoing Amateur operation or if they inidicate that they are a precursor for an incompatible allocation proposal. EXPs are more often problematic for one of these same reasons. They can be granted for up to five years but FCC is reluctant to grant EXPs for more than two years at a time. FCC's fear is that some entities will attempt to implement a commercial service via an EXP rather than seek an allocation by rulemaking. The problem that we have with EXPs is that we seldom hear of them until after they are granted. FCC does not notify us of EXPs or STAs in our allocations and does not put conditions on either that prior to operation, the holder of an EXP or STA contact ARRL for coordination purposes. FCC does that for broadcast auxiliary spectrum users, but they have not been responsive to our requess in the past to do this for us. We are going to renew our request for that accommodation. It is good spectrum management. An EXP with the call sign WH2XCI was granted to MITRE Corporation on October 1, 2014 for a two-year period to operate a total of 21 transmitters at each of ten discrete, fixed locations in New York State and Massachusetts for the purpose of testing high frequency (HF) communications in a variety of frequency bands from 2.5 MHz to 16 MHz. The purpose of the experimental operation is to test the “capability of higher bandwidth and higher data rate communications in the HF bands applying polarization diversity MIMO (multiple input, multiple output) concepts" for beyond line-of-sight propagation including ionospheric propagation. This is for “critical communications" which means it is research for the United States government, in all likelihood, for restoration communications. The HF bands to be used by MITRE include 2505-4100 kHz, 5005- 6210 kHz, 6320-8250 kHz, 10.005-12.200 MHz and 13.500-14.990 MHz. Power levels range from 6 watts to 122 watts with data bandwidths of 100 kHz, 500 kHz or 1 MHz. Obviously, this operation has a very high interference potential, so we wrote to MITRE's contact representatives (with a copy to FCC), told them that this was not on, and insisted that they confirm in writing that they will either (1) not use Amateur allocations, or (2) contact ARRL HQ before each and every test so that we can evaluate the interference levels and enforce the non-interference requirement on the EXP itself and in the Part 5 rules governing experimental authorizations. A copy of our letter to MITRE is attached. This morning, I received a confirmation from MITREs researcher that they have our letter and they will be responding to it. I will let you know what their response is. Let me know if you have any questions about this. Thanks to Dave Sumner for strategizing this, and for his good edits to the initial draft letter. 73, Chris W3KD -- Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG
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Christopher Imlay