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 Previous: FCC Amateur Radio Enforcement Letters for the Period Ending Mar 20, 2004 |  Next: Here's to the Control Operators |
NEWINGTON, CT, Mar 24, 2004--The ARRL has suggested that the FCC and National Telecommunications and Information Administration (NTIA) spectrum management professionals work more closely and cooperatively. It also called for more open allocation proceedings where federal/non-federal spectrum sharing is involved. The League offered the recommendations in comments filed on an NTIA Notice of Inquiry, "United States Spectrum Management Policy for the 21st Century." While the FCC oversees private and commercial spectrum, the NTIA--part of the US Department of Commerce--administers spectrum allocated to federal government users. It also advises the White House on telecommunications issues. ARRL said the current bifurcated spectrum management system has benefits and drawbacks.
"A significant advantage of maintaining the present scheme . . . is that the separate functions provide a system . . . of checks and balances," ARRL said, addressing whether spectrum management should be centralized. On the other hand, the League added, this separation can "delay needed action and promotes somewhat parochial and divergent priorities."
The FCC "has acted as a self-described 'cheerleader' for new, typically unlicensed, technologies without a firm grasp of technical compatibilities and incompatibilities," the League said. On the other hand, ARRL continued, the NTIA has tended to see its role as protector of the noncommercial spectrum it administers.
The FCC has been "inconsistent at best" in spectrum protection, ARRL said, while NTIA spectrum managers regularly provide "professional and impartial evaluations of new technologies" and their interference potential to government and shared government/non-government spectrum. Amateur Radio shares some of its allocations with federal users, especially in the UHF and microwave spectrum.
Given their "competing goals and interests," ARRL suggested that the FCC and NTIA adopt as a "best practices" guide a return to an approach that used to be standard operating procedure. In years past, the League said, "spectrum management officials of both FCC and NTIA worked closely and cooperatively," and there was regular staff-level communication between the two agencies.
The ARRL used the proceeding that led to the Amateur Radio 5 MHz (60 meter) allocation to emphasize its belief that spectrum management and sharing should operate according to "negotiated rule making procedures" in which all stakeholders participate. Last-minute NTIA intervention led to the current five-channel allocation at 5 MHz instead of the band the ARRL had sought and the FCC was poised to grant.
"The process for considering new federal and non-federal sharing plans should be more open than it currently is," the ARRL asserted. "There was no procedure for ARRL, FCC and NTIA (or the individual agencies concerned about this allocation) to meet and address potential concerns." Lacking any public procedure, the League said, the NTIA and FCC instead agreed to a compromise that was "inadequate for the purpose."
The ARRL said a negotiated rulemaking procedure could address such issues more quickly and efficiently than current procedures permit.
The League also took the opportunity to air concerns associated with the introduction of unlicensed spectrum users. "ARRL continues to urge that unlicensed low-power and unintentional radiators should not be permitted without due regard to their impact on existing radio services" or for their "unintended susceptibility" to RF from licensed radio transmitters, the ARRL said.
ARRL suggested having an independent laboratory or lab network evaluate proposed technologies prior to any FCC or NTIA frequency allocation proposal. "A good application for such a laboratory," the League said, "would be to evaluate the interference potential of Broadband over Power Line (BPL) systems, where the stakeholders are in rather substantial disagreement about the interference potential from radiated emissions from overhead lines" to HF and low VHF frequencies. The NTIA is currently evaluating BPL but has not yet released the results of its studies.
Comments in response to the NTIA NOI,
including ARRL's, are available on the NTIA's spectrum reform
Web site.
| Previous: FCC Amateur Radio Enforcement Letters for the Period Ending Mar 20, 2004 | Next: Here's to the Control Operators |
