I can become a bit... motivated when I am perturbed and so I went spent way too much time reading FCC filings and composing a very long winded comment but (I feel) well researched comment. I will be submitting it shortly but posting it here for posterity.
I am currently licensed as an Amateur Extra Class Operator, N1WBV , a member of the Amateur Radio Relay League, and an active user of the 902-928 MHz band (33cm band). I would respectfully request that the FCC reject the petition from NextNav Inc. (NextNav) as it will irreparably harm Amateur Radio operations in the 33cm band, especially FM and digital operation using Part 90 equipment reconfigured for Part 97.
Over the past two decades, the 33cm band has seen a large amount of growth within the Amateur community. This growth has been accelerated by the experimentation of Amateurs in Southern New England and Southern California working with the United States military in its use of the 420-450 MHz band (70cm band) with its Precision Acquisition Vehicle Entry Phased Array Warning System (PAVE PAWS) radiolocation service. The Amateur community coexisting and working with PAVE PAWS has been a partnership since 2006, predating NextNav’s founding. By eliminating significant amounts of equipment in the 70cm band in Southern New England and Southern California to support the military’s use of PAVE PAWS, Amateurs in those areas looked for other opportunities and bands to support communications projects.
Amateur use of the 33cm band is one the community and the Commission should be proud of. Realizing that commercial radio equipment certified under Part 90 of the FCC rules support frequency bands just above and below the 33cm band allocation, several experiments were conducted by Amateur Radio operators to determine if the equipment could be reconfigured for use under Part 97 within the 33cm band itself. Certain models of radios and equipment were found to be easily modifiable to utilize the edges of the 33cm band, transmitting at approximately 902 MHz and receiving at approximately 927 MHz. This allowed the equipment to be used under Part 97 and the 33cm band to be easily used by Amateurs. This information was shared across the Internet and demonstrated that the 33cm was a lot more accessible than previously thought.
Once this information was discovered and disseminated, the growth of 33cm started to take off. In Southern New England, Amateurs have further experimented with setting up a large scale linked repeater network from scratch using both digital (P25) and analog (FM) voice modes over both RF and Radio over IP (RoIP) services. The New England Amateur Radio 900 MHz (NEAR-900) Network consists of eighteen repeaters in three states, with coverage into all Southern New England states. This effort has been funded out of pocket by Amateurs and is truly a great example of what can be done by the Amateur community.
The 33cm band experimentation is a shining example of the purpose of Amateur Radio as defined by Part 97.1(b) and Part 97.1(d). Several Amateurs have advanced the art of radio by finding new “off label” uses for equipment and also have given many Amateur Radio operators, myself included, experience with Part 90 equipment, learning how to use, configure, and troubleshoot them as well.
One of the less touted success stories that I personally find notable about this effort in the 33cm band is what I deem “technology reclamation”, namely the reuse of used Part 90 equipment that has been deemed surplus by the original buyer. By using equipment that is no longer acceptable for use in mission critical situations such as public safety or critical infrastructure, Amateur Radio operators have saved tens of thousands of pounds of equipment from the scrap pile and turned into electronic waste (e-waste). In this day and age of electronics that are considered disposable, this is a model that should not just be acknowledged but celebrated and replicated.
In addition to digital and analog voice modes, the 33cm band is also active in digital data networks as well. The Amateur Radio Emergency Data Network project is doing its own kind of technology reclamation and taking Part 15 WiFi devices and using custom firmware to modify those devices for use under Part 97. Some of these devices use the 33cm band which is exceptional for longer range links where 2.4 GHz and 5.8 GHz are incapable of working. This equipment utilizing this band can be critical for establishing data links during a disaster.
Finally, separate from Amateur Radio, there has been a nascent grassroots effort with Part 15 devices in the 33cm band using the Low Power, Wide Area (LPWA) LoRAWAN specification by the LoRA alliance. The Meshtastic project, aiming to create a “open source, off-grid, decentralized, mesh network built to run on affordable, low-power devices” is becoming popular among non-licensed citizens. On an average day, there are approximately 2500 Meshtastic nodes across the continental United States connected to the Internet and many others that are independent of the Internet. This is an excellent tool for not only Science Technology Engineering and Mathematics (STEM) education but is also starting to be leveraged by the Amateur community as a gateway into the Amateur Service as well.
If the FCC grants NextNav’s petition for reconfiguring the 33cm band, it will result in all these efforts being destroyed by a stroke of a pen. NextNav’s petition labels the 33cm band “underutilized” and handwaves away Amateur Radio concerns in a single sentence stating “Updating the Lower 900 MHz Band M-LMS framework will not impede amateur operations.” I am saddened that NextNav tries to make it seem like the Amateur community doesn’t care about the 33cm band by pointing to an ARRL post and editorial about our secondary allocations above 420MHz. NextNav states that it understands “that most (if not all) non M-LMS equipment is frequency agile and (2) a contiguous 11-megahertz block will still be available for non-M-LMS operations—without any co-channel operations from NextNav.” This statement demonstrates a lack of “ground truth” as to the current types of utilization of the 33cm band that has been described in this comment.
In addition to this, NextNav states in their petition that “coexistence… should be achievable” with Part 15 device and that they are “completing technical analysis to address… Part 15 usage.” The phrasing used by NextNav suggests that their research into Part 15 devices is incomplete. This, combined with their lack of understanding of the current state of the 33cm band indicates that they have spent more time considering what works for their company rather than what works for the spectrum as a whole.
If the Commission grants NextNav’s petition, the slivers of spectrum at the top and bottom of the 33cm band that Part 90 equipment can effectively use under Part 97 will be reassigned to NextNav. This will obliterate the success that the Amateur community has had on 33cm and drop the utilization of the 33cm band significantly lower than current use. This is not in the best interest of effective Spectrum management. In addition to this the reassignment will cause thousands of pounds of e-waste to be generated as any Part 90 equipment modified for use under Part 97 for the 33cm band will become useless, which is not in the best interest of environment as well.
I respectfully recommend that NextNav's Petition for Rulemaking be denied.
Thank you
Benjamin Jackson, N1WBV
If you are active in 33cm, or just want to take an active role in throwing elbows for our allocations, I would recommend that you file a comment. Please feel free to use any of my research.