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ATN Comments to the FCC ET Docket 19-138

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ATN Comments to the FCC ET Docket 19-138 Before the Federal Communications Commission Washington, DC 20554 In the matter of ) Use of the 5.850-5.925 GHz Band ) ET Docket 19-138 ) Comments of Amateur Television Network - Arizona Chapter I. Introduction and Summary: 1. The Arizona chapter of Amateur Television Network (ATN-AZ) is part of ATN, the nation's largest Amateur Radio-Television group of clubs. Our members have four ATV re - peaters, three of them linked via microwave covering central, southern and eastern Arizona. We have shared the band well with government Radiolocation in the microwave bands for more than twenty years. Our linked repeater system is available to local and federal goverment EOCs to allow them to see emergencies in real time. 2. ATN-AZ is opposed to reallocating the bottom 45 MHz of the 5.9 GHz band to part 15 Wi-Fi devices. It is our opinion there is adequate space for Wi-Fi in the current alloca - tions. There are other studies for much larger spectrum reallocations for Wi-Fi in the 6 and 7 GHz bands. Our chapter has an ATV repeater FM output and link on 5910 MHz from White Tank Mountain west of Phoenix. This connects to our repeater at Mesa Arizona then on to Mt. Lemmon near Tucson. So far we have been able to share this spectrum with primary users of the band with no interference issues. Maintaining a low noise and low interference band is criti - cal for amateur television and other amateur radio operations to provide our mission of public service. II. Discussion: 3. Amateur radio and television operations has co-existed with ITS operations that Congress enacted in 1998. Furthermore, Congress continues to fund ITS since 1998. In the docket, the question of existing DSRC systems and the proposed CV2X system, spectrum needs for each is asked. ATN-AZ has reviewed many of the documented DSRC systems in use and CV2X as proposed in this proceeding. It is our opinion that the full 5850-5925 MHz band would be needed to allow room to develop both systems. We agree with the proposed CV2X operational power levels should follow that of the existing DSRC systems. ATN-AZ is currently operating our 5910 MHz FM output with no interference to or from ITS. 4. Sharing the 5.9 GHz band with Wi-Fi devices would cause our amateur television operations as well as other amateur radio operations to suffer harmful interference. This is the current situation amateur television and mesh systems experience in the 5.6-5.8 GHz band. For example, Our 5.712 GHz FM link from Mesa to White Tank suffers interference while the 5910 MHz from White Tank to Mesa and other locations has none. Most of the part 15 Wi-Fi devices being frequency agile do not have output filtering to reduce adjacent and semi-adja - cent channel spectrum re-growth and white noise. The lack of output filtering compounds the situation worse at co-located radio sites. It should be noted that most outdoor Wi-Fi devices are capable of half watt transmitter output power and connected to high gain antennas. Conse - quently, the effective radiated power routinely exceeds FCC rules, because many users disre - gard the requirement to reduce transmitter power to remain compliant. The combination of significant effective radiated power and spectrum re-growth cause significant interference to in - cumbent operations in the band. III. Conclusion: 5. ATN-AZ opposes reallocating the lower part of the 5.9 GHz band to part 15 Wi-Fi devices. Amateur operations do co-exist interference free with ITS operations within the band. Furthermore, not adding part 15 Wi-Fi operations the existing 5.9 GHz band allocation will allow ATN-AZ to continue supporting public service operations to local government and federal agencies during emergencies. Respectfully submitted by, Kevin Jacobson AD7OI, Trustee of ATN-AZ’s station W7ATN 1102 W. Aster Dr., Phoenix, AZ 85029.
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