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ARRL General Bulletin ARLB025 (2017)

ARLB025 FCC Seeks Comments on Technological Advisory Council

QST de W1AW  
ARRL Bulletin 25  ARLB025
From ARRL Headquarters  
Newington CT  December 5, 2017
To all radio amateurs 

ARLB025 FCC Seeks Comments on Technological Advisory Council

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 Public Notice is in PDF format on the web at,

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 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

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

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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