PLEASE submit your comments on Docket 19-348

This Commission has made it clear that high speed wireless communication is a priority.  After all, that is what this proceeding is all about.

After reading the release from this Commission regarding Kari’s Law, it seems that the ability to communicate during an emergency is also of the utmost importance.

AREDN, the Amateur Radio Emergency Data Network, does both; it provides a robust, high speed wireless communications network to support served agencies during times of emergencies.  Thousands of Amateur Radio operators are currently participating in this network, which is expanding every day.  With each additional node, the network expands its reach, becomes more robust, and a stronger tool to support served agencies. 

The success of the AREDN network is due to the Amateur Radio frequency allocations in the 3GHz and 5GHz bands.

Suitable radio equipment is readily available for use on the current Amateur allocations in both of these bands, and allows use in spectrum that is free from competition with unlicensed consumer devices.  The rulemaking proposed by this Commission therefore, poses an existential threat to AREDN.

It seems, given its stated desire to further high speed wireless communications, and to promote reliable communications  in times of emergencies, that this Commission would be in full support AREDN, and protect both the 3GHz and 5GHz spectrum that it has come to rely on.

I therefore urge this Commission to preserve the existing Amateur Radio spectrum in the 3GHz and 5GHz bands.

As an American Veteran and Life Time First Responder, and an Emergency Communications Professional, I strongly urge the FCC to prevent any reductions or impacts to the existing Amateur Radio Bands and activities in and around the 2.4, 3.4, and 5.8 GHz bands.

For decades, we in the Emergency Operations and Disaster Response Communities, both Paid and Volunteer, have been in urgent need of reliable and available high data rate, multi-media, IP-based communications systems, especially in austere, wilderness and disaster environments.

These radio bands are presently essential to existing and emerging infrastructures and services which have not been available until recently. And NO, FirstNet and other government and commercial infrastructures have not been, and will not be, adequate, proliferated, economic, or suitable for all or even the majority of such Operational Mission Needs, in all or even many of the expected or emergent geographic areas of need, especially after a major disaster, crisis, or attack.

As an excellent example of demonstrated successes for Public Services in these radio bands, at present, and for the foreseeable future, the most suitable technology is offered by the AREDN (Amateur Radio Emergency Data Network) "MESH" systems. They are presently implementing extremely flexible, resilient, robust, and capable IP-based high performance infrastructures, and they are independent of the internet, yet can leverage the internet, IF it survives. They are inherently survivable, and they are optimized for rapid deployments, self-organization, self-reconstitution, support for fixed and mobile platforms, and many other essential characteristics.

Furthermore, AREDN and similar technologies are already existing, and are being rapidly proliferated, as survivable networks of automated nodes across large areas of the Nation, and even World Wide, with standardized and interoperable protocols. These AREDN systems are essentially independent of the common telecommunications networks (internet, landline, cable, wireline, telephone, fiber, satellite, etc.), which have well know vulnerabilities and deficiencies, especially under duress. AREDN and MESH type systems have already been successfully and extensively demonstrated in disasters, crises, major events, and other situations.

In full accordance with the Public Service and Emergency Communications Purposes of Amateur Radio, in many regions of the Nation, Volunteer AREDN Teams have even been incorporating nodes for Emergency Backup Communications (Data, VoIP, Chat, cameras, etc.) in Local, State, and Regional Emergency Operations Centers, Emergency Rooms, Public Safety Centers, Relocation Facilities, and other vital locations. And independent of the vulnerable traditional infrastructures.

Virtually all of these outstanding accomplishments and successes have been at essentially zero cost to any government agency, and they are providing technology and services that arguably greatly exceed the conventional systems, especially in austere and disaster environment.

Yet, these outstanding benefits and performances are vitally dependent on continued and assured availability of the concerned 2.4, 3.4, and 5.8 GHz bands.

Why senselessly cripple an outstanding and valuable National Emergency Communications capability?

We again respectfully urge the FCC to prevent any reductions or impacts to these essential bands and their critical activities.

Thank You!

Done. Again.