ARRL met by telephone with FCC staff members this week to emphasize its opposition to the FCC proposal (Docket No. 19-348, in response to which ARRL filed comments in February 2020) to delete amateur radio from the 3.3 – 3.5 MHz band. The FCC will take final action in the proceeding when it meets on September 30.
ARRL urged that the secondary status for amateur radio in the band be continued. In a series of meetings with Commissioner legal advisors and staff members, ARRL explained how continued secondary use by radio amateurs will not impair or devalue use of this spectrum by future primary licensees, including those intending to provide 5G or other services. ARRL also stressed the various public-benefit uses of the spectrum by amateurs, including ongoing use of television and mesh networks on the west coast of the US as part of efforts to contain wildfires.
With regard to interference potential, ARRL stated that amateur radio operators using these bands are technically proficient and have a long history of sharing with primary users in this and other bands without causing interference.
FCC staff expressed concern that because amateur operations in the band are less clearly defined than those of other services also operating on a non-interference in the band, they would be difficult to locate should interference occur. ARRL Washington Counsel David Siddall, K3ZJ, noted that Section 97.303(g), an existing amateur rule, could be amended or used to craft a notification requirement, if the FCC concluded that relying on other methods would be insufficient. The FCC participants indicated that such a requirement, in place of deleting the secondary allocation, would be given serious consideration. (Section 97.303(g) contains specific frequency-sharing requirements for the 2200- and 630-meter amateur bands.)
Siddall also pointed out that the Amateur Television Network (ATN) filed an email with the Commission that included a letter from the California Governor’s Office of Emergency Services (CALoes) describing amateur radio’s contributions, specifically calling out the need for 3.4 GHz access GHz and explaining why other bands are not sufficient.
ARRL also argued that, in any event, continued operation in the band should be permitted until and unless an actual potential for interference exists in a specific geographic area. ARRL said the FCC should not intentionally leave spectrum capacity unused during a build-out period that the Commission’s own proposal indicates will last for at least 12 years in some areas.
The record in the proceeding is now closed. Please be reminded that there can be no calls, emails, or filings to the FCC with regard to the issues under consideration until a final FCC Report and Order and Further Notice of Proposed Rulemaking is released. Release is currently expected to be within a few days after the Commission’s September 30 meeting. At that time, ARRL will evaluate the impact on amateur radio of the Commission’s decisions and consider what further action, if any, may be merited.