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ARRL General Bulletin ARLB030 (2016)

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ARLB030 ARRL Encourages Comprehensive Noise Floor Study

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ARRL Bulletin 30  ARLB030
From ARRL Headquarters  
Newington CT  August 16, 2016
To all radio amateurs 

SB QST ARL ARLB030
ARLB030 ARRL Encourages Comprehensive Noise Floor Study

In anticipation of an FCC Technological Advisory Council (TAC)
investigation into changes and trends to the radio spectrum noise
floor to determine if there is an increasing noise problem, ARRL
asserted that such a study is long overdue. The FCC Office of
Engineering and Technology (OET) announced plans for the TAC study
in mid-June and invited comments and answers to questions that the
TAC posed concerning the methodologies for such a study. The
League's comments also praised the TAC - an advisory group to the
FCC - for tackling the issue and expressed the hope that the noise
study might, for the first time, provide a useful, objective basis
for spectrum overlays and other future allocation decisions. ARRL
allowed that while a noise floor problem exists, "The magnitude of
this problem and the extent of it in the 21st century is virtually
unknown."

"The TAC and the leadership in this study initiative are to be
congratulated for finally undertaking what has been universally
determined to be necessary for well more than 2 decades," the ARRL
said. "The Commission should not have made spectrum management
decisions without this noise information, and it is unfortunate that
the initiative has been delayed this long."

The ARRL said that its members can be of use in gathering data for
the TAC noise study, but advised that any urgency in initiating the
study "be tempered by the prerequisite need to develop a
standardized and valid methodology for conducting the study," in
order to "obtain quantitative data regarding the noise floor in
various environments and trends over time," ARRL said.

ARRL said the focus of the TAC noise "study should be an accurate
determination of what noise levels exist in as wide a range of
indoor and outdoor environments as possible. It should, to the
extent possible, determine what types of noise are being found:
Broadband, non-specific noise; broad noise spectral peaks; broadband
digital noise; and noise occurring on discrete frequencies."

"We also hope that these comments will serve as a stimulus for the
Commission to re-evaluate its 'hands-off' policy with respect to the
most recalcitrant and unhelpful operators of incidental and
unintentional radiators which are causing long-term interference
problems, such as electric utilities," ARRL concluded. "The
unwillingness of the Commission to issue meaningful sanctions has
led to the virtual absence of any incentive to comply with the
Commission's Part 15 non-interference obligations."

ARRL pointed out that the FCC had requested that the TAC study the
noise floor in 1999 and propose new approaches to spectrum
management based on emerging and future technologies. "The TAC
concluded that it would be impossible for the Commission to engage
in effective spectrum management until it 'develop[s] a more
complete understanding of the current state of the radio noise
environment,"' ARRL recounted, noting that TAC urged the Commission
to immediately undertake a multi-part noise floor study and
cautioned it against implementing new spectrum management techniques
or initiatives without first concluding extensive studies.

"Yet, 16 years later, no such study has been conducted," ARRL said.
"Now, and for the past several decades, new noise sources are being
developed and have been developed and the proliferation of
electronic devices continues as fast as the technology and the
regulatory processes will allow." While many individual sources of
RF noise may be consistent with FCC rules, in some cases they may
negatively impact the overall electromagnetic noise environment,
ARRL said.

"Because the Commission's resources are woefully inadequate to
address RF noise through widespread enforcement of Part 15 and Part
18 rules governing RF emitters after the devices are deployed, the
only reasonable means of dealing with them is to enact and enforce,
ex ante, appropriate rules for RF emitters that are based on actual
knowledge of the noise floor and trends over time," ARRL said. "The
growing number of interference complaints indicates that any
increase in noise levels will result in harmful interference, so
these rules may need to require a decrease in the permitted limits
for emission to balance the aggregate noise potential of a growing
number of noise emitting devices."

The League's comments include a bibliography, "Articles Relating to
the Description, Impact and Study of Man-Made Noise," compiled by
ARRL Lab Manager Ed Hare, W1RFI.
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