SB QST @ ARL $ARLB008 ARLB008 ARRL Supports No Change to Table of Allocations for 45.5 - 47 and 47 - 47.2 GHz Bands ZCZC AG08 QST de W1AW ARRL Bulletin 8 ARLB008 From ARRL Headquarters Newington CT March 14, 2019 To all radio amateurs SB QST ARL ARLB008 ARLB008 ARRL Supports No Change to Table of Allocations for 45.5 - 47 and 47 - 47.2 GHz Bands The FCC has opened a brief window for public comment on recommendations approved by the World Radiocommunication Conference Advisory Committee (WAC). Comments are due March 18 on International Bureau Docket 16-185. The FCC said the short comment period was necessary to allow time to finalize the US position for submission to the upcoming meeting of the Inter-American Telecommunication Commission (CITEL). The Public Notice can be found in PDF format at, https://docs.fcc.gov/public/attachments/DA-19-172A1.pdf . Addressing WRC-19 Agenda Item 1.13, which serves to identify spectrum above 24.25 GHz that may be designated for International Mobile Telecommunications (IMT), ARRL has recommended no change in the 45.5 - 47 and 47 - 47.2 GHz bands, with hopes that commenters will agree. The 47 - 47.2 GHz band is allocated to the Amateur and Amateur Satellite services. ARRL and other no-change proponents point out that no sharing and compatibility studies were performed between IMT-2020 systems and the relevant incumbent services in the 45.5 - 47 GHz and 47 - 47.2 GHz bands, although sharing and compatibility studies for a number of incumbent services were required under Resolution 238 of World Radiocommunication Conference 2015 (WRC-15). "In the absence of ITU Radiocommunication Sector studies, the only sustainable conclusion is that it has not been demonstrated that the incumbent services in either band - the Mobile-Satellite Service, the Radionavigation Service, and the Radionavigation-Satellite Service in the 45.5 - 47 GHz band, and the Amateur and Amateur-Satellite services in the 47 - 47.2 GHz band - can be protected, as required by Resolution 238," asserts the proponents of View B, which sides with no change to the current allocations. "In this regard, the View A proposal to identify mobile spectrum in the 45.5 - 47 GHz band for the terrestrial component of IMT, and to allocate spectrum in the 47 - 47.2 GHz band to the mobile service and identify the same for the terrestrial component of IMT, is fatally flawed. The absence of studies in the responsible ITU-R task group leaves the proposals unsubstantiated and incapable of adoption." View B proponents, including ARRL, are urging the FCC to accept the proposals of the National Telecommunications Information Administration (NTIA) for no change to the Table of Allocations in the 45.5 - 47 GHz and 47 - 47.2 GHz bands. NNNN /EX