ARRL The National Association for Amateur Radio® in a recent filing encouraged the Federal Communications Commission (FCC) to listen to industry stakeholders about the detrimental impacts that changes to the 902-928 MHz band would have for current users.

The FCC is considering a petition by NextNav, Inc., a licensee in the 900-MHz Location and Monitoring Service (LMS), to reconfigure the 902-928 MHz band to obtain more spectrum for itself and replace the LMS with high-power 5G cellular and related positioning, navigation, and timing (PNT) services that would supplement GPS. ARRL filed comments opposing NextNav’s proposal in September 2024.

Read more: NextNav’s proposal on ARRL News (8/15/2024)
Read more: ARRL Defends 902-928 Amateur Radio Band (9/12/2024) 

ARRL’s latest filing [PDF] was submitted on May 13, 2025, by the association’s Washington Counsel in response to an inquiry initiated by the Commission to consider more broadly ways to improve and harden GPS. ARRL’s response echoes concerns of many others and underscores the need to improve and harden the current GPS system in a manner that doesn’t impact radio amateurs and other users of the 902-928 MHz band. The band supports an extraordinary number of unlicensed consumer devices used by consumers both inside and outside the United States with which radio amateurs co-exist.

ARRL strongly agrees with the many parties that point out in the record of this proceeding that, in working with its sister federal agencies on this issue, one of the Commission’s primary goals should be to ensure that existing services already operating in the spectrum, such as in the crowded 902-928 MHz band, should not be disrupted by complementary PNT if equal or better means are available. Many billions of unlicensed devices are in use to provide hundreds of applications and functionalities to the American public, and the number of devices and the functionalities that they provide continue to grow.

These devices coexist with amateur radio operations in the 902-928 MHz band but they as well as amateur radio operations would be displaced if a 5G-like PNT service was authorized to use this spectrum.

In the instant proceeding the FCC addresses GPS concerns holistically that also are being addressed by multiple other federal government agencies under the direction of the President.  ARRL emphasized the FCC’s expertise and role in making the best use of the spectrum resource.

We commend the Commission for initiating this proceeding to take a holistic approach to the problem and possible solutions thereto, rather than a piece-meal approach that might have led to systems that would unnecessarily use valuable spectrum with inferior results and take years longer to construct from scratch. The Commission is the civilian spectrum expert among the collection of agencies that are addressing this issue. We rely on the Commission to make clear the value of each megahertz of spectrum and the trade-offs in designating any particular band for the purpose of complementary PNT.

ARRL’s filing is intended to emphasize the public interest in protecting amateur and others’ access to the 902-928 MHz band and to highlight that other, less disruptive options are available for PNT.

ARRL will continue to defend amateur access to this and other threatened amateur allocations.

It’s not just broadcasters who are getting their say in the FCC’s “Delete, Delete, Delete” deregulation initiative.

The National Association for Amateur Radio (ARRL) has also filed comments, advocating for a modernization of the Part 97 Amateur Radio Service regulations. Their proposals include both previously submitted items and new requests that the ARRL said is centered on updating the rules to reflect technological advancements while preserving the foundations of traditional amateur radio practices.

“The soldering iron and discrete physical components used in past experiments often are replaced by a personal computer and coding knowledge to experiment with new techniques and functions,” the ARRL wrote.

Modernizing Technician class license privileges

The ARRL said that while digital technologies like FT8, RTTY and PSK31 have become integral to the Amateur Radio Service, entry-level Technician class license privileges have not been updated accordingly. It advocates for granting Technicians access to HF frequencies where digital modes are prevalent, which it says is crucial for introducing newcomers to the fundamentals of low-power communication and fostering self-training and emergency communication skills.

“The youth attracted to amateur radio today will become the wireless engineers and space scientists of tomorrow that are critical to our nation’s future if given a chance,” the ARRL wrote.

The ARRL references a February 2018 petition on this matter that has yet to see action. Their specific requests include phone privileges in the 3.900 to 4.000 MHz, 7.225 to 7.300 MHz and 21.350 to 21.450 MHz bands, as well as RTTY and digital privileges within current Technician allocations on the 80, 40 and 15-meter bands.

Addressing 80- and 75-meter subband imbalance

The ARRL noted the increasing use of digital modes leading to an imbalance within the 80- and 75-meter amateur bands. To improve spectrum efficiency and better accommodate the demand for digital modes, the association refers to their 2016 petition requesting adjustments to the subband boundaries.

Specifically, it proposed shifting the lower edge of the phone band upward to 3.650 MHz, allowing RTTY data in the 3.500-3.650 MHz range, aligning the ACDS subband with international practices at 3.600-3.615 MHz, and granting Novice and Technician licensees CW, RTTY and data privileges in the 3.600-3.650 MHz segment, with General and Advanced licensees also gaining access to this segment.

Deleting baud rate and bandwidth limits

The ARRL reiterated its support for the FCC’s ongoing Further Notice of Proposed Rulemaking that Radio World reported on in 2023 to eliminate baud rate and bandwidth limitations on specific amateur LF and VHF/UHF bands. It noted the widespread support for this change among commenters.

Additional areas of interest in the ARRL filing include:

• Deleting Obsolete Digital Code Limitations:  It proposes allowing amateurs to freely experiment with new, publicly documented and decodable digital codes.
• Deleting Amplifier Drive Limitation: The ARRL requests the removal of the 15 dB gain limit for HF amplifiers. It argues this rule, originally intended to prevent CB misuse, is now obsolete due to advancements in solid-state amplifier technology and restricts efficiency for U.S. amateurs.
• Deleting Obsolete Identification Requirement for Special Call Signs: The ARRL seeks to remove the requirement for operators using special event call signs to identify hourly with their assigned call sign.
• Implementing WRC-03 Third Party Rule Changes: The ARRL calls for aligning FCC rules with the 2003 World Radiocommunication Conference updates regarding third-party communication. The association points out that despite the international agreement removing the need for bilateral treaties for most third-party communication, the FCC still requires such agreements, hindering cross-border communication and emergency training.

“Technology has changed dramatically in the amateur radio domain, as it has in most other communications services, and the above requested rules deletions and modifications will foster the regulatory goals for the amateur service and continue to increase the amateurs’ historical experimentation and service in meaningful ways,” the ARRL concluded.

(Read the comments of the ARRL to the FCC, filed on April 11.)