The ARRL has challenged the FCC to “do more than talk the talk” with respect to an FCC proceeding now under way to accommodate vehicular radar applications on spectrum in 76-81 GHz range. In reply comments filed on April 20, the League rebutted assertions from some commenters, and contended that Amateur Radio and short-range vehicular radar, as proposed by Bosch LLC, are compatible at 77-81 GHz.
“ARRL is comfortable with and has embraced this conclusion,” the League said in its reply comments. In light of a “thoroughly vetted and adopted” International Telecommunication Union (ITU) study already on record, the League said the FCC cannot go along with the suggestions of some industry commenters to exclude Amateur Radio from the 77-81 GHz segment.
“To do so based only upon an assertion of ‘potential interference conflicts’ in the absence of any evidence of such in the record of this proceeding or prior related proceedings, would be an abdication of critical analysis indicative of a lack of reasoned decision making,” the ARRL told the Commission. Bosch, which worked with the ARRL in advance of its petition, has “tellingly disassociated itself” from other industry commenters who, the League said, “cite no actual evidence” that typical Amateur Radio usage in the 77-81 GHz band would be incompatible with short-range vehicular radar in that frequency range.
As it did in its earlier comments in the proceeding, the League stressed that the ITU study “definitively establishes the compatibility of automotive radar and Amateur Radio” in the spectrum at issue.
“Bosch’s pre-petition work with ARRL, the ITU study, and the comments in this proceeding filed by Bosch, ARRL and some individual radio amateurs active in the band establish that Amateur Radio is in no way incompatible with automotive radar at 77-81 GHz,” the ARRL said.
“It remains ARRL’s position,” the League contended, “that there should be no change in the Amateur Radio domestic primary allocation at 77.5-78 GHz, or in the secondary Amateur allocation at 77-77.5 GHz or 78-81 GHz in order to accommodate automotive radar systems at 77-81 GHz.” The ARRL also said no changes were necessary in the Amateur Service Part 97 rules to accommodate such compatible sharing. “ARRL reiterates that such is precisely the position of the United States in anticipation of consideration of WRC-15 agenda item 1.18 later this year,” the reply comments said.
The ARRL pointed out that the FCC, through Chairman Tom Wheeler, had challenged incumbent millimeter wave users “to approach new uses of and sharing arrangements…with an open mind.” The League met that challenge before Wheeler even issued it, its reply comments asserted.
“The unfounded concerns of previously unengaged commenters that short-range vehicular radar is incompatible with Amateur Radio, based only on fear and not on evidence, are not supported in the record, and are contradicted by studies that have actually been performed and vetted,” the ARRL said. ARRL and Bosch have walked the walk that Wheeler challenged millimeter wave incumbents walk, the League said. “The Commission must refrain from suppressing Amateur Radio in the 77-81 GHz band if it is truly committed to its stated millimeter wave policy beyond merely talking the talk.”