AMSAT Comments on FCC RM-9267

AMSAT has filed the comments below in response to the LMCC proposal to take 20 MHz of the 70cm band.

                               Before the
                      Federal Communications Commission
                         Washington, D.C.  20554
In the Matter of                   )
Petition Filed by the Land         )       RM-9267
Mobile Communications              )
Council to Reallocate              )
Portions of the Amateur 70 cm      )
Band to Land Mobile Use            )
     The Radio Amateur Satellite Corporation (AMSAT) respectfully
submits these comments opposing the petition filed by the Land Mobile
Communiccations Council.
1.  AMSAT, a not-for-profit District of Columbia corporation established in
1969, is the principal membership organization of the amateur-satellite
community in North America.  Our membership currently numbers about six
thousand.  Together with over thirty of our affiliated organizations
throughout the world, we have constructed, launched and operated over two
dozen satellites to date in the amateur-satellite service, of which many
are presently in operation.  These currently operational spacecraft include
one high-altitude, Molniya-type orbit transponder satellite capable of
sustaining two-way communication over terrestrial paths well in excess of
10,000 miles (AMSAT-OSCAR 10), several low-earth-orbit (LEO) digital
store-and-forward packet radio satellites, scientific and educational
payload satellites, LEO analog transponder satellites, and spacecraft
featuring combinations of these types of payloads.
2.  Additional satellites for the amateur-satellite service are planned, or
are presently under construction, by AMSAT and its affiliate organizations
in various countries.  Many of these groups are associated with
universities or have access to government or industry facilities in their
countries.  Indeed, owing to the worldwide and cooperative nature of
amateur radio, the construction of satellites for the amateur-satellite
service has emerged as an important means of technology transfer to
developing countries.  One not-for-profit organization, Surrey
Satellite Technologies Ltd., affiliated with the University of Surrey in
the United Kingdom; has built or aided in the construction of a number of
such satellites.  Over the next ten to twenty years, it is certain that
further proliferation of this highly beneficial activity will take place,
provided suitable spectrum is maintained for its use.
3.  AMSAT itself is currently working with amateur satellite construction
groups in nearly a dozen countries to build the fourth and most advanced in
a series of elliptical orbit amateur satellites called "Phase 3D".  This 
spacecraft is expected to be launched later this year on an Ariane launch
vehicle.  One of the principal frequency bands that Phase 3D will employ,
is the 435 - 438 MHz segment of the 70 cm band.  The spacecraft includes
both a transmitter and a receiver in this band, either of which can be
switched to use a high gain array or an omni-directional antenna.
4.  Another important project, which is destined to make heavy use of the
435 - 438 MHz amateur-satellite service allocation is amateur radio
involvement on the International Space Station (ISS).  Amateur radio has
been accepted as a payload for ISS and AMSAT, along with amateur groups
from a number of countries, is currently actively pursuing designs for
equipment to go aboard the Station.
5.  Unlike commercial satellite services for which the use of
geostationary spacecraft is economically feasible and common, the amateur
satellite service currently utilizes satellites in low Earth orbits or
highly elliptical orbits, which serve all, or most, of the globe with one
set of uplink and downlink frequencies.  For this reason, amateur satellite
frequency allocations must be coordinated internationally so that they are
available for use on a worldwide basis.
6.  Amateur satellites are also completely different from satellites built
for government or commercial applications in another way.  In the case of
commercial or government satellites, while the spacecraft is being
constructed and prepared for launch, suitable ground station equipment is
being developed and deployed.  Usually, both of these are funded and
directed by the same company or government agency.  This assures that the
ground equipment will be in place when the space segment comes on line and
the two will be compatible with one another.  This is not the case with
amateur satellites.  Amateur satellites are constructed by a
specific amateur group such as AMSAT, or a collection of such groups.
In planning the satellite, the constructors attempt to understand the
current and future capabilities and needs of individual amateurs
throughout the world, not just in their own country.  This often means that
they must compromise in the design of the satellite, frequently choosing
lower frequency bands and lower-speed data rates than would be optimal
otherwise.  This creates somewhat of a dilemma for amateur satellite
builders.  If the lower bands are too crowded and the higher bands present
too  great a challenge to people in poorer countries, the use of
intermediate bands such as 70 cm (435 - 438 MHz) becomes mandatory.
7.  The intense crowding taking place on the lower amateur bands available
to amateur satellites, necessitates the use of the higher bands for them.
Particularly bad is the situation in the 144 - 146 MHz band, in which the
amateur-satellite service is co-primary with the amateur service.  This is
the only portion of the VHF spectrum presently allocated to the amateur
satellite service by the ITU.  Because of intense usage by other amateur
applications, the only part of this band regularly used by the amateur
satellite service is 145.8 - 146.0 MHz. Co-channel and adjacent-channel
interference, a direct result of the intense crowding, is increasingly
making the band difficult to use for satellites, especially for the
relatively weak signal satellite downlinks.  In addition to legitimate
amateur use of the band; the ready availability of inexpensive equipment,
intended for the amateur market, has resulted in extensive use of this band
by non-amateurs for personal and commercial communications in many
countries, especially in Central America, Asia and the Pacific Rim, despite
ITU regulations to the contrary.  First-hand observations by radio amateurs
flying in space aboard the Space Shuttle and MIR have confirmed that this
is a significant and growing problem. All of this crowding in the 2 meter
band, makes migration to higher frequencies all the more urgent.  For this
reason, increased emphasis must be placed on their use, for future amateur
satellites, especially 435 - 438 MHz.
8.  Over a dozen presently operating satellites currently utilize the
435 - 438 MHz segment of the 70 band.  A significant portion of that
current satellite activity involves store and forward digital message
traffic originating in the amateur packet network system.  Thus, many
amateurs, who may not even know that their messages are going through
satellites, are utilizing satellite communication, whether they know it or
9.  Two internal problems facing amateur radio are also important here.
They are the proliferation of modes of operation, many inherently wideband
in nature, and the increasing number of amateur radio operators resulting
from the institution of the code-free license.  For example, several
manufacturers currently offer low cost amateur television transmitters for
the 420-450 MHz band.  As no such amateur television equipment is
manufactured commercially, for any of the amateur bands above 450 MHz, this
band receives the brunt of amateur television operation.  Many of these
commercial amateur TV transmitters, and most home constructed units,
transmit signals 8 MHz in width (both sidebands).  Thus, their operation
often causes interference to other amateur activities, including amateur
satellites in the 435 - 438 MHz amateur-satellite service band.
Effect of Favorable Action by the Commission on the LMCC Proposal
10.  AMSAT contends that, if the LMCC proposal for reallocation, or
sharing, of 420 - 430 MHz and/or 440 - 450 MHz, is implemented, even more
of the aforementioned amateur television operation, as well as other
amateur activity such as FM simplex and remote bases, will be forced into
the 435 - 438 MHz amateur-satellite service segment of the 70 cm band.
11.  Indeed, any spectrum lost by amateur radio puts additional pressure on
remaining spectrum.  Proof that the LMCC proposal seriously threatens the
amateur-satellite service segment at 435 - 438 MHz, by causing other
amateur activates to crowd into what remains of the band, can be found in
the fact that satellite operation in that segment has already been impacted
by the loss of 420 - 430 MHz in some parts of the country, as well as the
heavy use of amateur repeaters in the 440 - 450 MHz segment.  These factors
have already caused an increasing number of amateur television operators to
use frequencies in the vicinity of 435 MHz.   Thus, it is quite logical to
conclude that complete loss of 420 - 430 and/or 440 - 450 MHz; or
substantial sharing of them with PMRS operators, will have a an even
greater impact on satellite operations in this band.
12.  AMSAT is concerned that sharing between PMRS operators and terrestrial
amateur communication in the proposed band segments is not feasible.  As
stated in 14 below, it would be expected that the PMRS operators would
employ conventional FM, just as do the amateur voice repeaters in that part
of the spectrum.  Thus, each would occupy similar bandwidths.  In many
parts of the U.S. particularly the large cities, the amateur band from 440
- 450 MHz is already completely filled with amateur voice repeaters.  It is
certain that these same cities are the areas in which PMRS is especially in
need of additional space, and thus would be bear the brunt of any sharing
that might be attempted.
13.  The 430 - 420 MHz segment, in the portions of the country where it is
available, is widely used by amateurs for voice and data links, as well as
for amateur television.  It is almost certain that amateur repeaters, links
and amateur television operators, experiencing interference from PMRS
operators, operating in the proposed band segments, would seek to move to
the 430 - 440 MHz segment, including the 435 - 438 MHz amateur-satellite
service segment.  This kind of situation has already been shown to be a
significant problem in the many other countries of the world; where only
430 - 440 MHz, or parts thereof, is available for amateur operation, and
all modes must share this narrow band of frequencies.  In AMSAT's opinion,
acceptance of the LMCC proposal, will guarantee that the same bad situation
will exist here in the U.S. to an even greater extent than it does today.
Alternative Approaches to Meeting LMCC Perceived Needs
14.  The LMCC petition is unclear as to how PMRS would make use of the
spectrum they are seeking.  Nothing regarding the technology that would be
employed is covered in their filing.  One can only assume that conventional
FM would be utilized.  There is no discussion of the use of more modern
technology such as spread spectrum (SS) or amplitude compandored single
sideband (ACSSB).  Monitoring by AMSAT members has shown that ACSSB
equipment is being used in the 220 - 222 MHz band reallocated from the
amateur service several years ago.  Thus, it would appear that suitable
ACSSB equipment is available.
15.  AMSAT suggests that consideration be given to placing ACSSB channels
between existing FM channels in the bands already allocated to PMRS.
Eventually, all land mobile operation could be converted to ACSSB,
multiplying the number of available channels by a factor of 4 or 5.
Alternatively, the use of SS systems, overlaying  existing PMRS allocations
offers another possibility.
Conclusions and Recommendations
16.  Even though the proposal offered by LMCC does not directly address
amateur -satellite service allocations, AMSAT believes that its
implementation will have a major impact on amateur satellite operation in
this important band, both in this country and abroad.
17.  Furthermore, AMSAT contends that, in this instance, as in any other
situation which might Impact a band allocated to the amateur-satellite
service; consideration must be given to the potential impact that any
action taken might have in the rest of the world, as well as this country.
18.  For the reasons cited, the Radio Amateur Satellite Corporation
strongly urges that the Commission not consider reallocating, the frequency
bands proposed by LMCC to PMRS, or allowing sharing by PMRS with current
amateur operations in these bands.  Further, we urge that LMCC explore
other frequency band alternatives and/or newer technologies that would
permit them to meet their needs using the frequencies already allocated to
them, before they seek the use of amateur frequencies.
Radio Amateur Satellite Corporation
P. O. Box 27
Washington, D.C.  20044
     William A. Tynan
May 29, 1998

Radio Amateur Satellite Corporation Board
American Radio Relay League
Land Mobile Communications Council

The deadline for reply comments to the FCC is June 15, 1998.  See ANS Bulletin 98-151.1 for details on how to comment.