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-...
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=H...
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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