The ARRL has commented on two draft recommendations of the FCC’s 2015 World Radiocommunication Conference (WRC-15) Advisory Committee (WAC) as well as on a draft proposal provided to the FCC by the National Telecommunications and Information Administration (NTIA).

The ARRL expressed support for the status quo regarding an allocation to the Mobile Service for broadband applications at 3400-4200 MHz and 4500-4800 MHz, which is under consideration as part of Agenda Item 1.1 at WRC-15. The 3400-3500 MHz segment is allocated on a secondary basis to the Amateur Service in ITU Regions 2 and 3, with a secondary allocation by footnote in some countries in ITU Region 1. The League said advocates for the allocation have failed to account for the protection of existing services.

“[The] failure to even superficially address the protection of all existing services — including the Amateur and Amateur-Satellite services — is glaring,” the ARRL said. The WAC’s so-called “View A” — to make no change in the allocation — in part said, “The secondary nature of the Amateur Service allocation requires flexibility in frequency selection to permit an Amateur Service licensee to use the allocation and fulfill his or her obligation not to cause harmful interference to the numerous primary services, including the FSS [Fixed-Satellite Service].”

ITU-R Resolution 233, adopted at WRC-12, spelled out explicit requirements for the studies of the candidate bands, including sharing and compatibility studies with services already having allocations.” As the League noted in its comments, a relevant ITU-R Recommendation  states that additional sharing with the Amateur and Amateur-Satellite services should not introduce high signal density services in the spectrum at issue, and that sharing studies should consider the Amateur and Amateur-Satellite services’ needs for “weak-signal” reception.

The ARRL supported the FCC WAC view on Agenda Item 1.12 that the US not be added to international footnote 5.480 — basically an exception — to the Table of Allocations that could make part of the 10.0-10.5 GHz segment vulnerable to additional allocation for Fixed Service applications. The Amateur and Amateur-Satellite services have a secondary allocation in the band, and the Federal Radiolocation Service is primary. The proposed “footnote amendment,” the League argued, “plainly, clearly, and indisputably contradicts existing United States regulations.” The League’s comments accused Mimosa Networks, which has argued in favor of having the US sign on to the international footnote, of advancing an “illogical construction to obtain the result it desires.”

Mimosa Networks has petitioned the FCC to permit unlicensed Part 15 wireless broadband services in the 10.0-10.5 GHz band. In comments last year, the ARRL called Mimosa’s Petition “fatally flawed” and said it should be dismissed. Among other things, the League told the FCC last year that Mimosa’s Petition was inconsistent with a US footnote in the domestic Table of Allocations, and that alone was sufficient reason for the Commission to quash Mimosa’s request.

In its comments on WRC-15 Agenda Item 1.12, the League said that Mimosa did not raise an objection to the WAC’s initially adopted position until months after the comment deadline. The ARRL said the FCC should use its original position — and not a later one that includes Mimosa’s arguments — as the baseline for any discussions with federal agencies to reconcile the agenda item.

The League also said the NTIA was correct in proposing that regulatory changes for nanosatellites and picosatellites be addressed under standing Agenda Item 7 at WRC-19. Standing Agenda Item 7 addresses advance publication, coordination, notification, and recording procedures for frequency assignments pertaining to all satellite networks, the ARRL noted. “It is not necessary to complicate the WRC-19 agenda to accomplish such work,” the League concluded. The comments pertain to Agenda Item 9.1.8 at WRC-15, which follows up on a resolution adopted at WRC-12.