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ARLB008 Comments needed, Little LEO

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ARRL Bulletin 8  ARLB008
From ARRL Headquarters
Newington CT  February 14, 1997
To all radio amateurs

SB QST ARL ARLB008
ARLB008 Comments needed, Little LEO

Commercial satellite interests seeking access to bands below 1
GHz--including amateur allocations at 146 and 430 MHz--now have added
220 MHz to their ''wish list.'' For the first time, Little LEO
(low-earth-orbiting satellite) interests have proposed including
219-225 MHz in their list of desired allocations for the non-voice,
non-geostationary (NVNG) mobile-satellite service (MSS). The move was
contained in the industry's so-called ''flexible allocation proposal,''
delivered at the February 13, 1997, meeting of FCC Informal Working
Group (IWG) 2A. Little LEO targets now include 146 to 148, 219 to 225
and 430 to 450 MHz. The ARRL and AMSAT were among those objecting to
the concept, and the League is urging those who agree with their
position to comment to the FCC by March 4. IWG-2A has been preparing
draft proposals for the 1997 World Radiocommunication Conference
(WRC-97). These will be reviewed during a March 5 meeting of the
FCC's WRC-97 Industry Advisory Committee that is preparing draft
proposals for consideration by the United States as it gets ready for
WRC-97

The ARRL and AMSAT statement said the latest proposal affecting
amateur allocations in the 219 to 225 MHz segment came ''at the last
possible moment'' and ''without any technical support whatsoever.'' The
League and AMSAT pointed out that the little LEO proponents have had
more than a year to complete a technical study of the possibilities
of sharing with the amateur services in the 144 to 148 MHz and 420 to
450 MHz bands. ''They have not demonstrated compatibility for sharing
these amateur bands but over the evolution of their document have
proposed various 'new ideas' for use of these bands.''

The little LEO flexible allocation strategy for WRC-97--submitted as
IWG-2A/86 (Rev. 6)--is to propose broad allocations. The apparent
theory is that most administrations would find reasons to oppose
little LEO use of specific bands in the crowded spectrum below 1 GHz,
but that a broad allocation would permit different implementations in
different countries depending on local circumstances.

At the February 13 meeting, a coalition of spectrum
interests--including land mobile, amateur, broadcasting, and
military--opposed the flexible allocation concept on three grounds:
that the concept is simply an invention to avoid performing technical
sharing studies that would demonstrate the unfeasibility of sharing;
that it is inconsistent with decades of ITU allocations practices;
and that, if adopted, the concept would be counter to US interests.
The coalition document is identified as IWG-2A/107.

The ARRL and AMSAT submitted a further statement of opposition,
citing the absence of any technical studies that might support
sharing with the amateur service or the amateur-satellite service and
pointing out that the little LEOs have completely mischaracterized
the nature of ITU Resolution 640 regarding the use of certain amateur
bands in the event of natural disasters. The ARRL/AMSAT paper,
revised to reflect opposition to the late proposal to include 219-225
MHz, is identified as IWG-2A/108 (Rev. 1).

Amateurs also might find interesting the comments of the Department
of Defense, identified as IWG-2A/101 (Rev. 1). These address the 430
to 450 MHz segment the Little LEOs seek to share.

Anyone wishing to register support for the ARRL/AMSAT submission
should send a brief e-mail message to wrc97@fcc.gov. The Subject line
should say ''Reference No. ISP-96-005 IWG-2A.'' A simple statement to
this effect, ''I support the ARRL/AMSAT opposition to the NVNG MSS
flexible allocation proposal,'' will be included in the public record
and will help to drive home the point that there is broad-based
opposition to poorly conceived sharing proposals.

Please note. The proposals the League opposes are not FCC proposals,
nor are they endorsed by any other branch of the government. They are
industry proposals. The League's objective is to demonstrate there is
broad citizen opposition to the industry proposals, so the government
will not adopt them as US proposals. So, please don't ''flame'' the FCC
if you comment.

Additional arguments or evidence also is welcome. Important. Comments
should reach the FCC no later than March 4, 1997.

The complete ARRL/AMSAT opposition statement and other comments will
be posted by February 15 on the ARRLWeb page, http://www.arrl.org/
under Band Threat News.
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