The ARRL has expressed its support for three recommendations affecting Amateur Radio frequency allocations which the FCC’s World Radiocommunication Conference 2015 FCC Advisory Committee (WAC) has already approved. ARRL Chief Technology Officer Brennan Price, N4QX, filed comments on behalf of the League October 17 in IB Docket 04-286. The League has concluded that the WRC-15 Agenda Item 1.1 recommendation for 420-450 MHz “maintains a status quo that accommodates many users and works well.” The Amateur Service is secondary on the 70 centimeter band in the United States. At least one administration has proposed to introduce international mobile telecommunications (IMT) — cellular telephone and wireless broadband — to the bottom 10 MHz of the band, but the League said it agrees with the WAC and the NTIA that things are just fine as they stand.

“The status quo is successful and represents a success story for spectrum management,” the League said. “Introduction of IMT in the 420-430 segment of this band, as proposed by one administration, will most assuredly upset this status quo.” The ARRL pointed out that although ham radio is secondary on the band, “radio amateurs have a vested interest in maintaining their ability to use the band,” and Amateur Radio has been “a responsive and responsible sharing partner” to the band’s primary users.

For its part the WAC said, “The results indicate that for most cases, sharing between IMT-2000 base/mobile stations and the various types of radars when placed in adjacent spectrum is not feasible in the absence of mitigation.” Based on information at hand, the committee said, “it is logical to conclude that co-frequency sharing between IMT and the radiolocation service in the 420-450 MHz bands is not feasible.”

The League also said the WAC recommendation for WRC-15 Agenda Item 1.10 regarding 22 to 26 GHz “protects the only worldwide, primary Amateur and Amateur-Satellite Service allocation between 146 MHz and 47.2 GHz.”

“Sharing with incumbent services, including the Amateur and Amateur-Satellite services at 24.-24.25 GHz will require technical and operation constraints that will result in spectrum being impractical for use by the MSS [Mobile Satellite Service],” the ARRL said. The Amateur and Amateur-Satellite services are primary at 24-24.25 GHz. “Radio amateurs have been responsible stewards of a band that is difficult to use, and the WAC proposal of no change to the entire 22-26 GHz range is particularly applicable to the 24-24.25 GHz segment.”

WRC-15 Agenda Item 1.18 considers a primary allocation to the radiolocation service for automotive applications in the 77.5-78.0 GHz frequency band in accordance with a resolution adopted at WRC-12. The League suggested that the FCC support the WAC recommendations “as a base for eventual reconciliation with an NTIA position,” or that the FCC not support any position on the agenda item, “as conducted studies to not support a position more expansive than that contained in the recommendation.” The Amateur and Amateur-Satellite services are now primary in the 77.5-78 GHz band, with Radio Astronomy Service users secondary.