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

[Bart Kus]

Correction, the FCC docket # for this NRPM is 13-49.  The URL shown 
below still works, but re-directs to the new 13-49 URL.  If you go to 
http://apps.fcc.gov/ecfs/comment_search/ to search for comments on this 
matter, enter "Proceeding Number" 13-49.  There is one amateur radio 
comment already.  I have made the author aware of HamWAN's intended comment.

--Bart

On 3/14/2013 12:20 AM, Bart Kus wrote:
> 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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> PSDR at hamwan.org
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