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).

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. -- Thanks to Jon Siverling, WB3ERA