SB QST @ ARL $ARLB030
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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