[Ground-station] Draft comment - WT Docket No. 19-348

[Michelle Thompson]

https://docs.fcc.gov/public/attachments/DOC-360941A1.pdf

Second draft below. Please review.

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Open Research Institute (ORI) is a non-profit research and development
organization which provides all of its work to the general public under the
principles of Open Source and Open Access to Research. Our technical focus
is research and development for Amateur Radio and Amateur Satellite
Services.

Microwave band spectrum allocation needs renovation. The continuing growth
of mobile and cellular service is not the only compelling reason. Setting
aside significant and globally coordinated bandwidth for  the Amateur Radio
Service and Amateur Satellite Service is mission critical for an educated,
creative, and competent American engineering workforce. Amateur Radio
provides the best, least expensive, and most effective way of engaging
students and citizens in communications theory and practice. Without an
accessible way for people of all walks of life to experiment and learn with
microwave-band communications, we are at a distinct competitive
disadvantage at a critical time.

Hundreds of volunteer developers have been working for the past three years
on geosynchronous satellite uplinks on the amateur microwave bands. An
amateur satellite service geosynchronous payload has been deployed at 25.9°
E with coverage of Europe, Africa, and parts of Asia. This payload, called
QO-100, has a 2.4 GHz uplink and a 10.5 GHz downlink. Open Research
Institute was founded to design open source amateur radio satellites in the
microwave bands using digital modes. There are no geosynchronous amateur
satellite service payloads over North America. Open Research Institute is
dedicated to correcting this.

Open Research Institute is aware of no current payload using the 3.40 to
3.41 GHz amateur satellite segment. The most recent technical effort in the
Amateur Radio community that we are aware of with a 3GHz amateur satellite
uplink was halted in 2009 due to unaffordable launch costs. The 3.40 to
3.41 GHz satellite segment is currently avoided by most, if not all,
amateur radio satellite teams because it is not available in all ITU
regions. Another significant factor is how this band is described. It is
always introduced as "under threat." This is a very important factor for
expensive and ambitious work such as 3 GHz amateur satellite utilization.
The amateur service is non-commercial by definition. If people are going to
take on enormous risk to design and build something as an avocation, then
the additional risk in choosing a band that is not well-coordinated, or
might be yanked out from under the engineering team, is a lot to ask.


Recommendations


1) Allow the Amateur Satellite Service to keep their current allocation at
3.40 to 3.41 GHz for space-to-space communications.


Why?

This is a useful inter-satellite frequency and would in no way interfere
with the ground-based 5G. 3 GHz is expected to be important for lunar to
Lunar Orbiting Platform Gateway (LOP-G) relays. We expect data received on
3 GHz will be transmitted over a 10 GHz DVB-S2 downlink.

2) Amateur allocation in other bands should be increased to compensate for
the loss of 3.40-3.41 GHz.

Why?

To improve spectrum access for Amateur Satellite Service at 5 GHz, 10 GHz,
and 24 GHz. 10 MHz of microwave spectrum in these bands would be very
beneficial. Allocation won't harm the services currently or proposed to be
using those frequencies.

Why is this important?

Growth in mobile and cellular microwave broadband has benefited greatly
from amateur radio operators. Amateur radio needs adequate access to
appropriate spectrum and some degree of certainty that it will remain
available. Without spectrum, amateur radio cannot continue to attract,
inspire, and support interest in advanced digital communications.

The commercialization of the microwave bands has lowered the price of
microwave components and test equipment. This has enabled tremendous growth
in microwave-band amateur radio. The number of amateur microwave contests,
new amateur microwave distance records, and the rise of organizations such
as Open Research Institute are all proof of substantial high-tech activity.
This volunteer technical corps provide enormous civic and technical value
to culture and the economy. The only requirement is a very modest amount of
reserved spectrum.

If 5G can be described as golden eggs, then the geese that laid them
include large numbers of amateur radio clubs, groups, mentors,
experimenters, and teachers. These often-uncredited influencers helped
create a generation of engineers willing to take the risks that resulted in
the creation of the world's most successful communications system.

Just one example is Joe Taylor, K1JT. Some of his very influential work
includes Earth-Moon-Earth communications and advanced digital signal
processing modes WSJT, JT65, and FT8. Joe credits amateur radio for
inspiring his interest in science.

For more, see
http://www.princeton.edu/~paw/archive_old/PAW95-96/02_9596/1011feat.html

The FCC must be willing to pay it forward so that the next generation can
benefit even more.

That means increasing the commitment to educational and avocational
opportunities in microwave band engineering theory and practice. The best
possible way to do this is to make the microwave bands amateur-friendly to
the maximum practical extent.
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