Subj : ARRL Urges Protecting the Amateur Radio 902-928 MHz Band

Subj : ARRL Urges Protecting the Amateur Radio 902-928 MHz Band
To : QST
From : ARRL de WD1CKS
Date : Fri Aug 23 2024 10:09 pm

08/15/2024

The Federal Communications Commission (FCC) accepted for public comment a
Petition for Rulemaking filed by NextNav Inc.,[1] a licensee in the 900-MHz
Location and Monitoring Service (LMS), to completely reconfigure the 902-928
MHz band and replace the LMS with high-powered 5G cellular and related location
services.

The FCC Notice requested comment[2] on the effects that NextNav's proposals
would have on amateur radio operations in the band. ARRL� The National
Association for Amateur Radio�[3] is preparing comments urging protection of
existing and future amateur uses in this band and urges all amateurs to file
their own comments describing their activities in this band and the expected
effect of the proposed changes. Click here for a guide to filing comments.[4]

NextNav currently holds licenses in the 900-MHz band that authorize it to
provide services limited to determining the location and status of mobile radio
units. NextNav ties its request to provide high-power broadband, cellular and
location services to the vulnerabilities of the current satellite-based GPS
system and argues that implementation of its proposal would complement GPS by
providing an alternative nationwide terrestrial location system in addition to
cellular and broadband services. Under its proposal, NextNav would be
designated the sole nationwide licensee for this spectrum in exchange for its
more limited licenses.

The new nationwide license would authorize NextNav to provide much
higher-powered traditional broadband and 5G cellular services as well as the
related location service occupying 15 of the total 26 megahertz available in
the band. The reconfiguration proposed by NextNav would create a
5-megahertz-wide uplink subband at 902-907 MHz paired with a 10-megahertz
downlink subband at 918-928 MHz.� The 5-megahertz uplink subband would be
limited to use by mobiles with a maximum of 3 watts ERP.� On the 10-megahertz
downlink subband, up to 2000 watts ERP would be permitted in rural areas and
1000 watts ERP in urban and suburban areas, radiating from tower structures
that could reach 1000 or more feet above average terrain. These configurations
reflect the FCC's rules for standard cellular configurations that have been
adopted to govern a number of other bands used for similar 5G and like
services.

Although uses by the Amateur Radio Service in this band are secondary to LMS,
NextNav is proposing substantial technical and use changes that would
completely alter the foundation upon which the current rules and spectrum
sharing arrangements rely and undercut shared use of the band by amateurs as
well as a variety of other users. In addition, NextNav proposes deletion of a
specific interference provision in the Commission's rules that was adopted to
encourage and protect continued sharing with amateurs and other secondary
users.

NextNav, in its petition, argues without evidence that the changes that it
proposes to the 902-928 MHz band "will not impede amateur operations."� In an
8-page description[5] of NextNav's proposal released by the FCC's Wireless
Telecommunications Bureau, the FCC staff asks a series of questions that would
clarify the proposal and help the Commission ascertain the likely effect of the
proposed changes on existing users if the requested changes were adopted.
Comment was specifically requested on the extent of amateur operations in the
band, the potential impact of the proposed changes, any other spectrum options
that may exist, and the costs for relocations if other options exist.

ARRL is preparing comments urging protection of existing and future amateur
uses in this band.� ARRL urges all amateurs to study the proposal and file
their own comments describing their activities in this band and the expected
effect of the proposed changes. The filing deadline is September 5, 2024.
Replies to comments are due by September 20, 2024.� Click here for a guide to
filing comments.[6]

[1] https://www.fcc.gov/ecfs/document/10416238018537/1
[2] https://docs.fcc.gov/public/attachments/DA-24-776A1.pdf
[3] https://www.arrl.org/
[4] https://www.arrl.org/arrl-guide-to-filing-comments-with-fcc
[5] https://docs.fcc.gov/public/attachments/DA-24-776A1.pdf
[6] https://www.arrl.org/arrl-guide-to-filing-comments-with-fcc

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