Before the

Federal Communications Commission

Washington, DC 20554

In the matter of )

Facilitating Shared Use in the 3.1-3.55 GHz Band ) WT Docket 19-348

)

Comments of Amateur Network – Arizona Chapter

I. Introduction and Summary:

1. Since 1999, the Arizona chapter of Amateur Television Network (ATN-AZ) has been part of ATN, the nation's largest -Television group of clubs. Many Arizona ATVers operated for decades before that. We joined up with the ATN-CA group in California because we had so much in common.

In Arizona, we have twelve Full Members and fifty-seven Associate Members, three -linked ATV and one standalone ATV covering most of the populated area of Arizona. In the near-future, we plan to install microwave ATV links to additional cities in Arizona and to California. In the meantime, we link over the . We had hoped to use the 3 GHz band for the new RF links because it is the best band we have for ATV.

We have shared the band well with government Radiolocation in the microwave bands for many years. Our linked repeater system is available to county, city, state and non- governmental agencies like American Red Cross and CERT. RACES and ARES groups can utilize our equipment in the field or they can ask for assistance from our ATV operators during emergencies and exercises.

2. The ATN Arizona chapter strongly opposes removal of 3.3-3.5 GHz from the Amateur Radio Service. Removal of this band would halt our plan to install a 3380 MHz FM ATV repeater output at our Thunder Mountain, Mesa location, which would better serve the eastern Phoenix metro area. We have already purchased equipment for this installation. Removal of this band would also halt our plan to install a 3480 MHz FM ATV repeater output at our Mt Lemmon, Tucson location, which would better serve the

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Tucson metro area. We were prepared to purchase equipment for this installation but stopped short when we learned of this docket. Removal of this band would also put a halt to our plan to install a 3480 MHz FM ATV repeater output at our White Tank, Phoenix location, probably about a year from now, if we can still use 3 GHz spectrum.

ATN-AZ has integrated ATV and Mesh Networking (Mesh ) together to take advantage of the best features of both modes for audio and video. Our statewide Mesh Networking group, Arizona Mesh Organization (AMO) has planned several 3 GHz backbone links to interconnect cities in the Phoenix metro area as well as Wickenburg and Prescott. Our plan is to bridge Mesa, south Phoenix, west Phoenix, Wickenburg and Prescott together serving all communities around those locations and in-between. This would greatly extend our coverage and provide higher-quality audio/video signals and data. We halted this project when we became aware of the 3 GHz docket and may have to scrap it completely because there is no practical alternative to using our current 3 GHz spectrum for Mesh Networking. This Mesh expansion is intended to serve hospitals, the American Red Cross and other important community services. Losing the 3 GHz spectrum would be a major setback for their plans.

Although it would be costly to modify our already-purchased 3380 MHz ATV equipment, if we had to relocate elsewhere in the 3.1-3.55 GHz band, we would prefer that to the loss of 3.3-3.5 MHz band with no replacement spectrum. A partial solution would be allowing Radio Amateurs to use the new 20 MHz-wide guard band channel at 3980- 4000 MHz as noted in the new 3.7 GHz Report and Order.

Though the above relocation might be a partial solution for ATV, there is no relocation that would allow Mesh Networking backbones to function at all because the equipment that is currently available doesn’t work in any spectrum that is being suggested for relocation.

The best and only practical solution for Radio Amateurs is to leave the 3 GHz band allocation as it is or allow us to at least continue to use a significant part of it. That is much preferred over relocating spectrum, which would only be a partial solution. Worst of all would be the complete loss of the 3 GHz allocation, which would significantly impair the service we can provide and the quality of our communications.

Although there are other microwave bands in the Part 97 allocation, several of those bands have been greatly reduced in size and have new or reactivated L band ARSR-4 RADARS that we have to protect from interference. Part 15 Wi-Fi systems have overlaid most of the other useful microwave bands. The 902-928 MHz, 3.3-3.5 GHz and 5.650- 5.925 GHz bands have large numbers of Amateur Mesh nodes and Wi-Fi access points taking up the remaining space in each band, reducing the number of channels for ATV. ATV signals are very vulnerable to Mesh Networking and Wi-Fi interference. Those

Comments from Amateur Television Network – Arizona Chapter Page-2 devices continuously, even if no user data is being transferred. Because of that, we need to allow significant guard bands to isolate the signals and that requires us to use up more spectrum than might otherwise be expected.

II. Discussion:

3. In the docket under section III, Discussion, subsection A (9): "Removal of Non-Federal Allocations", it is discussed about the commercial interest in the band as well as extensive uses by STA's and experimental licenses operating in the 3.1-3.55 GHz band. Missing is any mention of Amateur Radio Part 97 use of the band although our use is in the public view. Amateur Radio operations in the 3.3 -3.5 GHz band include but are not limited to Amateur Television repeaters and links, Mesh nodes, Wi-Fi access points, weak signal terrestrial, Amateur Satellite and earth-moon-earth (EME). EME allows international microwave communications with stations running high power and large dish antennas.

4. In the docket under section III, Discussion, subsection B (11): "Future of Incumbent Non-Federal Operations", The question of where to relocate incumbent non- federal users is asked. ATN and the other amateur radio users would prefer to stay in our existing allocation in the 3.3-3.5 GHz band. That said, perhaps part of that allocation could be spared like what the Commission has done in the recent 3.7 GHz Report and Order, dividing the original FSS (TV C-band satellite) 3.7-4.2 GHz band between existing FSS at the top of the band and reallocating the bottom half to and other commercial interests. From the 3.7 GHz report and Order, the resulting 3980-4000 MHz guard band channel could be allocated to Radio Amateurs as a replacement ATV channel. Replacement spectrum in the 3.1-3.3 GHz band may work for ATV and weak signal modes but may be an issue internationally using Earth Moon Earth to communicate with amateurs in other countries. Mesh equipment will not work below 3.35 GHz, a major issue for that mode.

5. In the docket under section III Discussion, subsection B (12): "Future of Incumbent Non-Federal Operations", The question, "Is there sufficient spectrum in existing amateur spectrum in other bands that can support operations currently conducted in the 3.3-3.5 GHz band"? Certainly not in Arizona. ATV and Mesh amateur operations are wideband and occupy every usable channel that is not occupied by Part 15 devices.

ATN is using the following bands:

420-450 MHz - 70 cm band:

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434.0 MHz is our original ATV simplex from the 1970s and we now use it as a repeater input. We need to avoid transmitting any significant energy in the amateur satellite 435-438 MHz sub-band. Using VSB (filtered AM) analog ATV, we have most energy in the video carrier at 434 MHz and the aural carrier at 438.5 MHz. Almost all of the transmitted signal is outside the satellite allocation. To our knowledge, there has never been a report of satellite interference from our ATV transmissions. We are also running 434 MHz DVB-T digital ATV with 2 MHz so we don’t interfere with weak signals in the 431-433 MHz sub-band or with amateur satellite in the 435-438 MHz sub-band. There isn’t enough spectrum available on this band for high quality ATV (FM ATV or 6-MHz Digital) operation in Arizona. Our 434 MHz ATV inputs are often interfered with by spread-spectrum signals seeming to emanate from Luke Air Force Base in west Phoenix. We have no remedy for that interference.

902-928 MHz - 33 cm band:

Due to heavy Part 15 device usage and utilities using Part 15 smart meters, we have been unable to operate ATV successfully in this band. When we tried, we were able to receive strong ATV signals but they were obliterated by other strong signals that tore up the picture and scrambled the sync, making it totally unusable. Even at high power levels, we were unable to override the interference.

1240-1300 MHz - 23 cm band:

This band is increasingly hostile to ATV use. Our White Tank ATV repeater output is on 1253.25 MHz VSB. We are plagued with bursts of interference that we believe might be from radar somewhere southwest of Phoenix. This interference varies but often makes the signal almost unusable. There seems to be no practical remedy. We considered using the 3 GHz band for an interference-free output instead but stopped that plan because of this docket.

2390-2450 MHz - 13 cm band:

2417.5 MHz FM ATV is one half of a link pair, the other in-band duplex link channel has XM there now. Currently, we use 2417.5 MHz as an ATV link from Mesa to Tucson. We frequently get interference but haven’t been able to determine the source yet. 2441.5 MHz is the FM ATV repeater input for all of the ATV repeaters in Arizona. We often have to tolerate significant interference from Wi-Fi users. This band used to be ATV-friendly but it no longer is.

3300-3500 MHz - 9 cm band:

ATN uses 3380 and 3480 MHz FM ATV as repeater outputs because they provide higher resolution pictures than VSB. 3380 and 3480 MHz are interference-free and work

Comments from Amateur Television Network – Arizona Chapter Page-4 better with clearer pictures and longer range reception than 900 MHz, 1.2 GHz and 2.4 GHz-band ATV repeater outputs and links that experience significant interference. For that reason, we have made plans and already purchased some equipment to use 3380 and 3480 MHz as FM ATV repeater outputs. We have halted these projects until we learn the outcome of this docket.

5650-5925 MHz - 5 cm band:

ATN has a White Tank 5910 MHz FM ATV repeater link to Mesa. Mesa links back to White Tank on 5712.5 MHz FM ATV. White Tank occasionally experiences Wi-Fi interference on 5712.5. These don’t work as well as we would like because of the high levels of interference in this band. The frequencies in this band aren’t adequately coordinated and many Mesh users aren’t aware where we operate ATV. There is a large amount of 5 GHz Mesh operation that continues to increase, leaving virtually no 5 GHz spectrum available for ATV expansion.

III. Conclusion:

6. ATN-AZ opposes complete removal of the Amateur Radio Service Part 97 allocation in the 3.3-3.5 GHz part of the 3.1-3.55 GHz band. We would prefer that this spectrum continue to be allocated to Radio Amateurs as it is. If the allocation must be changed, ATV users need at least 40 MHz of 3 GHz spectrum for two 3 GHz-band interference-free ATV channels that don’t need to be contiguous. Mesh operations need at least 60 MHz to operate and weak signal, EME users and amateur satellite operators need a few MHz. 3 GHz is the only interference-free band we have. Please don’t take it all away.

Respectfully submitted by,

Rodney S Fritz, ATN-AZ Vice President

8334 E Culver St, Mesa AZ 85207

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