SB SPACE @ ARL $ARLS002
ARLS002 AMSAT Cites Need for Adequate Spectrum in Opposing Deletion
of 3.4 GHz Band

ZCZC AS02  
QST de W1AW  
Space Bulletin 002  ARLS002
From ARRL Headquarters  
Newington, CT  February 27, 2020
To all radio amateurs

SB SPACE ARL ARLS002
ARLS002 AMSAT Cites Need for Adequate Spectrum in Opposing Deletion
of 3.4 GHz Band

AMSAT has commented on the FCC Notice of Proposed Rulemaking (NPRM)
in WT Docket 19-348 that proposes to delete the 3.3 - 3.5 GHz (9
centimeter) amateur band and relocate incumbent non-federal
operations. The band includes the 3.40 - 3.41 GHz Amateur Satellite
service allocation. In its remarks, AMSAT said it opposes deletion
of the allocation and stressed the necessity of having adequate
microwave spectrum available for future amateur satellite projects,
including AMSAT's GOLF program and the Lunar Gateway. AMSAT
acknowledged that the 3.4 GHz Amateur Satellite service allocation
is not currently used by any amateur satellites and that it is
unsuitable for worldwide communication because it is not available
in ITU Region 1. AMSAT said a number of potential future uses for
the band remain, however, as worldwide usage of other available
allocations increases.

AMSAT's comments can be found online in PDF format at,
https://www.amsat.org/wordpress/wp-content/uploads/2020/02/Comments-of-Radio-Amateur-Satellite-Corporation-WT-Docket-No-19-348.pdf
.

"These potential uses include a future amateur satellite in
geostationary orbit above the Americas," AMSAT said, explaining that
the segment could support uplink or downlink frequencies for such a
spacecraft without potential interference to worldwide activities
involving space stations in high-earth or lunar orbit. The
most-desirable allocations for use as uplinks are between 2.4 GHz
and 5.67 GHz - 80 MHz in all, AMSAT told the FCC. "As many of the
proposed uses include amateur television and high-speed data
transmission with satellites in high-earth orbit or lunar orbit,
these allocations may quickly become inadequate," AMSAT said.

AMSAT told the FCC the 3.40 - 3.41 GHz allocation could be utilized
as a command channel or secondary data downlink for AMSAT ground
stations in ITU Region 2 without interfering with the primary
communications on the other allocations or other satellites
utilizing those segments.  AMSAT said several non-amateur satellites
use the broader 3.3 - 3.5 GHz amateur allocation, which also sees
wide use for amateur radio mesh networking, EME communications, and
contesting.

"The amateur satellite service continues to provide immense value to
the growing field of small satellites," AMSAT concluded.
"Experiments conducted by amateur satellites...continue to inform
the development of the commercial small satellite industry.
Additionally, student participation in amateur satellite projects
provides both inspiration for young men and women to pursue careers
in the commercial satellite industry and practical experience for
those careers.

"A strong and robust amateur satellite service will continue to
benefit the public interest and inspire future developments in
satellite technology," AMSAT said. "Continued progress in achieving
these goals requires adequate spectrum, especially in suitable
microwave bands."
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