SB QST @ ARL $ARLB025
ARLB025 FCC Seeks Comments on Technological Advisory Council Recommendations

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

SB QST ARL ARLB025
ARLB025 FCC Seeks Comments on Technological Advisory Council Recommendations

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,
http://transition.fcc.gov/Daily_Releases/Daily_Business/2017/db1201/DA-17-1165A
1.pdf .

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 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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