In a Public Notice released on December 1, the FCC’s Office of Engineering and Technology (OET) has invited comments by January 31, 2018, on a wide-ranging series of Technological Advisory Council (TAC) recommendations that, if implemented, could alter the spectrum policy regulatory landscape — especially with respect to interference resolution and enforcement. An advisory body, the TAC’s membership includes several Amateur Radio licensees. ARRL will file comments in the proceeding, ET Docket 17-340.
The TAC has called on the FCC to:
- Consider adopting the spectrum management principles spelled out in the Council’s Basic Spectrum Principles white papers of March 2014 and December 2015, and set “set clear expectations about the affected system’s capabilities regarding interference, such as harm claim thresholds.”
- More broadly adopt risk-informed interference assessment and statistical service rules. “In judging whether to allow new radio service rules, the TAC observes that the Commission has to balance the interests of incumbents, new entrants, and the public,” the Public Notice explained. “The process of analyzing the tradeoffs between the benefits of a new service and the risks to incumbents has, to date, been essentially qualitative.”
- Implement “a next-generation architecture” to resolve interference, and establish a public database of past radio-related enforcement activities. The TAC also recommended that the FCC “incorporate interference hunters in the [interference] resolution process.”
The TAC spelled out a set of three “Interference Realities,” which, in part, assert that harmful interference “is affected by the characteristics of both a transmitting service and a nearby receiving service in frequency, space, or time,” and that radio services should expect occasional service degradation or interruption.”
The TAC also posed three “Responsibilities of [Radio] Services that, in part, state that “receivers are responsible for mitigating interference outside their assigned channels” and that “transmitters are responsible for minimizing the amount of their transmitted energy that appears outside their assigned frequencies and licensed areas.” The TAC acknowledged that the FCC, by and large, does not regulate receiving systems.
Another three principles under “Regulatory Requirements and Actions” the TAC suggested that the FCC may “apply interference limits to quantify rights of protection from harmful interference.” According to the Public Notice, the TAC “has recommended interference limits as a method for the Commission to communicate the limits of protection to which systems are entitled, without mandating receiver performance specifications.” The TAC called for a “quantitative analysis of interactions between services” before the FCC could “make decisions regarding levels of protection,” The OET said.
“[T]he TAC believes the principles can be applied to all systems and result in an optimal solution for each service,” the Public Notice said. The TAC has suggested that the FCC not base its rules on exceptional events and worst-case scenarios but on reality.
“The TAC recommends that the Commission start soon, and start small, and not attempt a major overhaul of its regulatory approach,” the Public Notice said.
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