AMSAT Files Comments Opposing Deletion of 3.4 GHz Band

AMSAT has filed comments on the Federal Communications Commission’s Notice of Proposed Rulemaking which proposes to delete the 3.3 – 3.5 GHz (9 cm) amateur band, including the 3.40 – 3.41 GHz amateur satellite service allocation.

In the comments, AMSAT opposes the deletion of this allocation and emphasizes the necessity of adequate microwave spectrum for future amateur satellite projects, including AMSAT’s GOLF program and the Lunar Gateway.

AMSAT further notes that the most desirable allocations for use as uplinks are the allocations between 2.4 and 5.67 GHz. These allocations total 80 MHz. The most desirable allocation for downlink use is the 10.45 – 10.50 GHz allocation, totaling 50 MHz.

As many of the proposed uses include amateur television and high-speed data transmission with satellites in high earth orbit or lunar orbit, these allocations may quickly become inadequate. AMSAT also notes that the 2.4 and 5.67 GHz allocations are widely used for ISM and consumer devices, such as WiFi and Bluetooth-enabled devices. The 3.4 GHz allocation is shared between amateur use and other non-federal and federal licensees, but is free from the unpredictable interference of consumer devices.

While acknowledging that the 3.4 GHz amateur satellite service allocation is not currently used by any amateur satellites and that it is unsuitable for worldwide communication since it is not available in ITU Region 1, AMSAT identifies a number of potential future uses for the band as worldwide usage of the other available allocations increases. These potential uses include a future amateur satellite in geostationary orbit above the Americas.

In the comments, AMSAT also noted several non-amateur satellite uses of the broader 3.3 – 3.5 GHz amateur service allocation, including its wide use in mesh networking, EME communications, and contesting.

The full text of the comments as filed can be downloaded at https://tinyurl.com/ANS-054-FCC