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

[Michelle Thompson]

Update to include Nobel Prize for Joe Taylor, from Douglas Quagliana (one
of the first round editors).

Thank you to everyone contributing review input!

-Michelle W5NYV




On Mon, Dec 9, 2019 at 12:45 PM Michelle Thompson <
mountain.michelle at gmail.com> wrote:

> Update with content from Wally Ritchie.
>
>
>
> Recommendations
>
>
> 1) 1) Allow the Amateur Satellite Service to keep their current allocation
> at 3.40 to 3.41 GHz for space-to-space communications and expand this
> allocation to 50MHz within the existing amateur 3.30 to 3.50 GHz allocation.
>
> 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 forwarded over a 10 GHz DVB-S2 downlink.
>
> Amateur Radio use of 3.4 GHz for space-to-space links to space-based relay
> stations can enable development of new technologies and techniques to more
> efficiently utilize spectrum in space while posing negligible interference
> to uses on the ground.
>
>
>
>
> On Mon, Dec 9, 2019 at 10:50 AM Michelle Thompson <
> mountain.michelle at gmail.com> wrote:
>
>> https://docs.fcc.gov/public/attachments/DOC-360941A1.pdf
>>
>> Second draft below. Please review.
>>
>> -=-=-=-=-=-=-=-=-=-
>>
>>
>> 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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