[HamWAN PSDR] HamWAN Response to FCC NPRM 13-22

[Bart Kus]

For those unfamiliar with the issue, we are dealing with the FCC 
removing protections of Amateur Radio spectrum in the 5GHz band.  I have 
attached the exact (lengthy) FCC publication which announces this 
intention.  Page 6 shows the graphical view of what they're proposing.  
Paragraph 97 on page 31 covers details of U-NII-4 rules, which sums up 
to it's OK to run high power, and it's OK to run it outdoors.  This is 
big trouble for amateur radio in this band, as amateurs will be denied 
entry onto sites that use this spectrum for unlicensed but commercial 
reasons.  We cannot compete with the money changing hands between 
commercial WISPs and site owners.

Below is what I've drafted as a response to this proposed ruling. Please 
read it over and comment.  We only have a few weeks to file the response 
and generate popular support to sway the FCC's opinion.  Please spread 
the word through the amateur radio community.  I have posted this 
message on our website at:

https://www.hamwan.org/t/tiki-index.php?page=HamWAN+Response+to+FCC+NPRM+13-22&structure=HamWAN

for easy sharing with others.

*HamWAN Response to FCC NPRM 13-22*

The new U-NII-4 band allocation and U-NII-3 25MHz expansion for 
unlicensed users will cause many problems for Amateur Radio networks 
operating in that spectrum.I would like to point the commission to an 
example of one such band plan for the HamWAN network:

https://www.hamwan.org/t/tiki-index.php?page=Spectrum+Allocation&structure=HamWAN

To summarize the spectrum here textually, it is:

Guard Band: 5.835-5.845GHz

Channel 3 @ 240 degrees azimuth: 5.845-5.865GHz

Guard Band: 5.865-5.875GHz

Channel 2 @ 120 degrees azimuth: 5.875-5.895GHz

Guard Band: 5.895-5.905GHz

Channel 1 @ 0 degrees azimuth: 5.905-5.925GHz


This arrangement allows co-existence of Amateur Radio digital networks 
on high up and densely populated radio sites, alongside commercial 
wireless service providers.

It has been HamWAN's experience that site owners, when deliberating 
Amateur Radio admission onto such sites, are primarily concerned about 
the impact to these unlicensed commercial wireless service providers.So 
even though Amateur Radio licensing in the 5.65-5.925GHz range 
technically allows priority access to these frequencies for amateurs, 
the reality of the situation is the exact opposite.Financial benefit to 
tower site owners is the true arbiter of spectrum usage at prominent 
sites.Amateurs have no chance of competing with commercial spectrum 
interests in this band.The U-NII-4 allocation, and the 25MHz U-NII-3 
expansion effectively deny access to the frequencies for amateur usage 
at sites required for network creation.

Given that there is great momentum behind deploying these free-to-use 
amateur networks right now, this will force the amateur community into a 
contentious position with the unlicensed commercial users of the 
spectrum, particularly at popular tower sites.Amateurs will be forced to 
use the only tool left available to them, and that is to file complaints 
of interference against the unlicensed users until their operations at 
popular sites are either shut down or moved to different spectrum.

HamWAN would like to achieve a peaceful co-existence with existing 
wireless network providers, by leveraging the amateur portion of the 
5GHz spectrum as much as possible, before opportunistically sharing the 
rest of the U-NII spectrum.This view of cooperation is shared by other 
amateur organizations.

In summary, please consider the value that non-commercial microwave 
networks delivered by amateurs provide to their communities, and please 
revert the U-NII-4 allocation along with the 25MHz U-NII-3 expansion.We 
do not oppose the other changes in NPRM 13-22.

Signed,

Bart Kus

HamWAN Chairman


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