FAA's Spectrum Management Activities May Be Getting "Adult Supervision"
If you’re sitting on a plane at the gate and reading this column on an electronic gadget, you’re about to hear eight dreaded words: “Please power down your electronic devices for takeoff.” But this time next year, you might hear something very different: “Please put your devices on ‘airplane mode’ for takeoff.”
In a phone interview, Ms. McCaskill said she had grown frustrated with the F.A.A.’s stance on devices after she learned that the agency now allows iPads as flight manuals in the cockpit and has subsequently given out devices to some flight attendants with information on flight procedures.
“So it’s O.K. to have iPads in the cockpit; it’s O.K. for flight attendants — and they are not in a panic — yet it’s not O.K. for the traveling public,” she said. “A flying copy of ‘War and Peace’ is more dangerous than a Kindle.”
Now maybe if NTIA were more aggressive with FAA in asking it to justify their spectrum management decisions this mess might never have happened. Perhaps if the recommendations of Chapter 5 of the PCAST spectrum report were implemented there would be more accountability by all federal agencies for their spectrum management decisions.
Thanks, Mr. Akin!
GAO Receiver Report
The report repeats that FCC in general lacks authority to regulate receivers and that NTIA has such authority with respect to federal users. Buried in page 20 of the report is the fact that FCC was able to creatively use its limited power to create a de facto receiver immunity standards in the 800 MHz band to help solve the Nextel/Public Safety problem:
For example, FCC defined the minimum levels of performance that a receiver must meet to make a claim of harmful interference in the 800 MHz band.
Thus FCC could take similar additional steps in other bands without new legislation.
The report accepts without questioning NTIA’s claimed efficiency at setting receiver standards, but doesn’t ask the question how certain NTIA is about whether federal systems actually meet those standards. Since NTIA does not have an equipment authorization systems, how is compliance verified?
Finally, it gives not mention at all the long standing FCC/NTIA/FAA dispute over receiver immunity standards for Instrument Landing System receivers. While receiver standards are difficult to develop, in the ILS case there is an ICAO Convention standard that FAA will not required for all aircraft in the US because of would offend AOPA, the NRA-equivalent for general aviation. (Here is my fact sheet on this issue.)
The basic reason for this type of problem is that receiver standards are often an economic externality in which the party purchasing the improved receiver gets no tangible benefit. The GAO report does not delve into this issue at all!
NY Times: "The F.A.A. has no proof that electronic devices can harm a plane’s avionics, but it still perpetuates such claims" "Dealing with the F.A.A. on this topic is like arguing with a stubborn teenager"
Readers may recall that SpectrumTalk has repeatedly talked about the FAA’s renegade role in spectrum management: apparently not happy that Congress has split spectrum management between FCC and NTIA (with some international issues at State), FAA likes to impose itself as another coequal player in national spectrum management. Meanwhile NTIA for decades, glowing in its power derived from Section 305 of the Communications Act, has lacked the moral backbone and institutional authority to keep FAA in line with respect to national spectrum policy issues.
Recently the NY Times published the article whose heading is shown above. Here is a quote:
Dealing with the F.A.A. on this topic is like arguing with a stubborn teenager. The agency has no proof that electronic devices can harm a plane’s avionics, but it still perpetuates such claims, spreading irrational fear among millions of fliers.
A year ago, when I first asked Les Dorr, a spokesman for the F.A.A., why the rule existed, he said the agency was being cautious because there was no proof that device use was completely safe. He also said it was because passengers needed to pay attention during takeoff.
When I asked why I can read a printed book but not a digital one, the agency changed its reasoning. I was told by another F.A.A. representative that it was because an iPad or Kindle could put out enough electromagnetic emissions to disrupt the flight. Yet a few weeks later, the F.A.A. proudly announced that pilots could now use iPads in the cockpit instead of paper flight manuals.
Now FAA likes to say that the problem is “aggregation” - the impact of many emitters operating at the same time. But the real problem of aggregation comes from faulty technical analysis of the spectrum problems.
While aggregation can happen in some scenarios, e.g. terrestrial transmitters operating cochannel with a satellite uplink, real multipath propagation - as happens in most scenarios int he real world - results in lognormal propagation path losses in one or two emitters dominating the interference scenario and the others having no impact.
The Times points out that In December both FCC Chairman Genachowski and Senator Claire McCaskill (D-MO) both urged FAA to be more rational with respect to use of devices on aircraft. Sen. McCaskill even wrote that she was “prepared to pursue legislative solutions should progress be made too slowly.” She said she was urging the agency to embrace the use of electronics, including laptop computers, e-readers, smartphones and other devices, “during the full duration of a flight.”
“The current rules are inconvenient to travelers, don’t make sense and lack a scientific basis,” she said in the letter. “Airline employees have the incredibly important job of keeping us safe in the air. Their efforts are better spent worrying about rules that actually accomplish that goal.”
FAA likes to say that it is only obsessed with safety - an admirable goal if true. However, the sordid history of the FM/ILS affair also shows that FAA is just as concerned about the proprietary interests of “its constituency” - the airlines and AOPA - than it is of safety issues. Also the FAA’s bizarre 2006 NPRM, never coordinated with either FCC or NTIA, that proposed giving the agency veto power over both federal and nonfederal spectrum use in dozens of bands shows a fundamental misunderstanding of the public interest in spectrum.
So kudos to NY Times for their great coverage of this issue. When will NTIA and Congress pressure FAA to start acting more rationally on spectrum matters?
GAO Report on Spectrum Sharing
GAO writes,
While federal spectrum users often share spectrum among themselves, they may have little economic incentive to otherwise use spectrum efficiently, including sharing it with nonfederal users. From an economic perspective, when a consumer pays the market price for a good or service and thus cannot get more of it without this expense, the consumer has an incentive to get the most value and efficiency out of the good as possible. If no price is attached to a good—which is essentially the case with federal agencies’ use of spectrum14—the normal market incentive to use the good efficiently may be muted. (p. 11)
Actually while it is true that “federal spectrum users often share spectrum among themselves”, this is mostly due to pressure from Congress and OMB, not so much from NTIA leadership or the collective interest of federal agencies who generally would just like to have their own systems regardless of financial or spectrum efficiency. But the availability of “free spectrum” has warped the decision making process in federal agencies since the marginal cost of spectrum is always less than the marginal cost of more efficient technology.
Echoing the findings of the controversial PCAST report, GAO writes
We have previously reported that to improve spectrum efficiency among federal agencies, Congress may wish to consider evaluating what mechanisms could be adopted to provide better incentives and opportunities for agencies to move toward more efficient use of spectrum, which could free up some spectrum allocated for federal use to be made available for sharing or other purposes.
The report ends with 3 recommendations for FCC NTIA action:
• Report their agencies’ views and conclusions regarding spectrum usage fees to the relevant congressional committees, specifically with respect to the merits, potential effects, and implementation challenges of such a fee structure, and what authority, if any, Congress would need to grant for such a structure to be implemented.
• Based on the findings of current research and development efforts under way, determine how the federal government can best promote federal and nonfederal investment in the research and development of spectrally efficient technologies, and whether additional spectrum is needed for testing new spectrum efficient technologies.
• Evaluate regulatory changes, if any, that can help improve and expedite the spectrum sharing process.
Will this report have a major impact on spectrum sharing? Probably not. But this report adds to the weight of the PCAST report with respect to the problems of federal spectrum management. These problems arise not from the lack of public interest in the NTIA staff and IRAC membership, rather than the fact that the present 1978 NTIA structure is unrealistic in view of the current demands for spectrum from all public and private parts of our society and economy and the new technical options for sharing that just were not even a pipe dream when the 1978 framework was put in place in the Carter Administration.
Spectrum Policy for National Government Users: A Worldwide Policy Challenge
National governments around the world are generally large scale spectrum users for their military and civil governmental operations. Today, many governmental functions are spectrum intensive due to the increasing mobility and use of information in today’s societies and economies. The civil functions range from air traffic control to public safety operations to fixed and mobile wireless networks to support other functions that are key to toady’s societies. The spectrum resources that are used for such governmental functions are generally not available for private sector users, although some sharing is possible in classic spectrum policy. National government spectrum use is a difficult regulatory issue because the very same national government that is using such spectrum includes the regulator that sets the rules for private sector use. In many countries military authorities play a key role in national spectrum management.
Spectrum is generally fungible for national government and private sector use and is a key input to wireless systems that have a large impact on national economic growth which in turn impact national government revenues. This article will explore the policy challenge of regulation national government spectrum use and discuss a recent US report on the issue.
Different countries have chosen different mechanisms for balancing national government and private sector spectrum use. In Japan, the Ministry of Internal Affairs and Communications (MIC) is the unitary regulator of all spectrum use and consistent with the Japanese style of government deals with other agencies on a somewhat distant basis. In the US, spectrum policy responsibility is split between the independent Federal Communications Commission (FCC) with jurisdiction over private sector and local government use and the executive branch’s National Telecommunications and Information Administration (NTIA) with jurisdiction over national government use. In the United Kingdom the Office of Communications (Ofcom) has responsibility for the “communications sector” while the national government, acting through a little known official committee of the Cabinet Office, the UK Spectrum Strategy Committee (UKSSC), has responsibility for national security and public safety spectrum use.
In the UK, the government has stated that “public bodies will acquire spectrum through the market, with administrative assignment by Ofcom only being made in exceptional cases” and that “(t)he Government is committed to paying administered incentive pricing (AIP) on its spectrum holdings”. (AIP is an estimate of spectrum value based on spectrum scarcity and other factors. ) In the US and some other countries, national government spectrum users pay a small fee for spectrum use that is calculated only on NTIA’s administrative costs and is independent of free market spectrum value. Thus the UK is unique in the world for its progress in treating spectrum use by the national government basically on the same economic terms as private sector use. While this may seem unusual to people who have dealt with spectrum for a long time, national governments around the world generally pay market prices from other key resources and products they use ranging from electricity to fuel to vehicles to land.
In July 2012 the US President’s Council of Advisors on Science and Technology (PCAST) released a report on national government spectrum use policy entitled “Report to the President: Realizing the Full Potential of Government-held Spectrum to Spur Economic Growth” . Parts of this report has been very controversial within the US because it advocates limiting previously planned reallocations of national government spectrum to commercially-operated mobile broadband systems and focusing on accommodating commercial spectrum use on increased sharing of spatial and temporal bands by national government users and private sector users. But in addition to this controversial recommendation there are several other recommendations that have received little attention and may be applicable to situations in other countries.
The report finds that “(t)here is no incentive system today for Federal (national) Government agencies to be efficient in their use of spectrum or to share spectrum allocated to them with the non-Federal (private/local government) sector” and recommends that the “essential element of this new Federal spectrum architecture is that the norm for spectrum use should be sharing, not exclusivity.” Because much national spectrum use is different in temporal and geographic characteristics than much of the other use, it finds that sharing will be possible in many cases with the provision that non-national government users must change their spectrum use temporarily when and where there is a surge of national spectrum use, for example during military training exercises.
The report recommends that national government agencies using spectrum should be given incentives to decrease their spectrum use because increased spectrum availability for the private sector has real economic benefit. Generally government entities are subject to strict budget constraints that make it difficult to impossible to explore system design changes to existing systems that could lower their spectrum requirements. While US already now provides for agencies to be reimbursed for the cost of moving to new bands, the cash flow of agency expenditures to plan and implement such a change and the reimbursement to the agency do not match well in terms of timing and amounts.
The report suggests creating a revolving Spectrum Efficiency Fund that “recycles private sector payments for use of Federal spectrum into reimbursements to Federal agencies for investments that facilitate spectrum sharing and enhance spectrum efficiency. Congress should allow the Fund to reimburse qualifying costs by any Federal service, not just those in revenuegenerating bands.”
The new fund would not have the cash flow limitations of the present scheme that discourage agency investments in planning studies and small scale tests of new technology since they can not be reimbursed presently until the spectrum has been auctioned to private users – possibly years later. The report goes further in recommending a major accounting change to facilitate agency changes that make more spectrum available to others:
“Spectrum currency is our name for a synthetic currency that would give agencies a means to identify the opportunity costs associated with their use of spectrum and to obtain benefits by sharing or vacating some parts of their assigned spectrum and provide a way for them to “buy” their spectrum usage rights and reduce their spending by improving spectrum efficiency…To turn their gains in efficiency to practical advantage, agencies desiring to accelerate their transition to the new scheme could use their spectrum currency to bid every year for equipment credit from the Spectrum Efficiency Fund … that would enable them to increase their service quality.”
The UK has led the way in holding national government spectrum users more accountable for their spectrum use through the pricing of spectrum for most government and private spectrum users. The recent US PCAST report explores new options to try to balance the equities of national government and private sector spectrum use. These will generally be controversial in each country and it is important that the technical wireless community become familiar with the issues involved in order to contribute to national deliberations on what is the best approach for each country.
Frequencies Above 95 GHz: Why Not Declare that Section 7 Presumably Applies in Order to Stimulate US Innovation and Economic Growth?
135 GHz antenna developed by Singapore
government lab and announced last week
(The fact that this antenna looks so unusual is an
indication that technology at this band is very
different and conventional regulatory thinking
may be inappropriate.)
Almost on cue from my 8/25/22 post on moving the upper limit of FCC radio service rules above 95 GHz, RF Globalnet published on 8/28/12 a post entitled “A*STAR's IME Develops Smallest Antenna That Can Increase WiFi Speed By 200 Times”. A*STAR is the Singapore Agency for Science, Technology and Research, the “lead agency for fostering world-class scientific research and talent for a vibrant knowledge-based and innovation-driven Singapore” - somewhat of a combination of the US’ NSF and national laboratories (e.g. Argonne National Lab) in a state capitalism industry model. (Original A*STAR press release)
The RF Globalnet article reported (in Singapore/Commonwealth spelling):
Researchers from A*STAR’s Institute of Microelectronics (IME) have developed the first compact high performance silicon-based cavity-backed slot (CBS) antenna that operates at 135 GHz. The antenna demonstrated 30 times stronger signal transmission over on-chip antennas at 135 GHz. At just 1.6mm x 1.2mm, approximately the size of a sesame seed, it is the smallest silicon-based CBS antenna reported to date for ready integration with active circuits. IME’s innovation will help realise a wireless communication system with very small form factor and almost two-thirds cheaper than a conventional CBS antenna. The antenna, in combination with other millimetre-wave building blocks, can support wireless speed of 20 Gbps – more than 200 times faster than present day Wi-Fi, to allow ultra fast point-to-point access to rich media content, relevant to online learning and entertainment.
So the Japanese have a product prototype at 120 GHz that they used at the Olympics 4 years ago and a Singapore government lab is developing 135 GHz commercial technology. Where do US firms stand? There is some interest among US firms in this area. The US-based IWPC MoGig group includes several US entities such as AT&T and Northrop Grumman. But a rational “due diligence” assessment of regulatory risk by anyone wanting to invest in R&D in these bands would lead to great regulatory uncertainties at present:
- Only experiment licenses are possible with no guarantee of renewal or expectation of protection
- Unlicensed use is impossible
- The legality of equipment sales is questionable
- The time for FCC to respond to a waiver request or a petition for rulemaking to permit a specific product to be sold and used in these bands is in the multiyear range and the need for NTIA coordination (all these bands are G/NG shared) is complicated since there is no public information on federal government uses or requirements in these bands other than radio astronomy and passive sensing
Recall the words of Comm. Pai in his maiden speech at CMU in July:
I’ve met with those in the private sector who decide whether to make investments and to create jobs and have asked what’s holding them back. The principal answer that I have received has been remarkably consistent, and it can be summed up in two words: “regulatory uncertainty.”
Some of the factors that contribute to this uncertainty fall outside of the FCC’s jurisdiction, such as taxes, health care, and financial regulation. But concerns are expressed regarding the FCC in two general ways. The first involves inaction, or delayed action, by the Commission. At first blush, it may seem odd for those in the private sector to be complaining that its regulator is moving too slowly. Entrepreneurs are usually happy to be left alone, free to innovate without government intervention.
But the communications industry often doesn’t fit that stereotype given the FCC’s pervasive role. If a company wants to market a new mobile device, it needs the FCC’s approval. If a company wants to purchase another firm’s spectrum licenses, it needs the FCC’s approval. If a company wants to provide a new wireless service, it needs the FCC’s approval. And if a company finds that there isn’t any spectrum available and proposes the reallocation of inefficiently used spectrum, it needs the FCC’s approval.

Comm. Pai has the same understanding of Section 7 that I have:
“Looking at that provision, the message from Congress is clear: The Commission should make the deployment of new technologies and new services a priority, resolving any concerns about them within a year.”
It is interesting to read Section 7(a) (47 USC 157(a)) in the light of the FCC/NTIA Section 301/305 dichotomy and in view of the fact that any action in these shared bands de facto requires NTIA concurrence. Without the benefit of any formal legal education, let me state that the policy provisions of Section 7(a) applies to both FCC and NTIA. Further, the requirement that
Any person or party (other than the Commission) who opposes a new technology or service proposed to be permitted under this chapter shall have the burden to demonstrate that such proposal is inconsistent with the public interest.
would indicate that NTIA (and IRAC) is a “person or party other than the Commission” and thus has “burden to demonstrate that such proposal is inconsistent with the public interest”.
But here is a humble suggestion:
Why don’t FCC and NTIA jointly declare that any proposed private sector use of frequencies greater than 95 GHz will be presumptively treated as a “new technology or service” and that FCC and NTIA will both strive to meet the 1 year deadline of section 7(b) and the burden tests of Section 7(a)? Further, why doesn’t FCC use the same “shot clock” for tracking such actions as it already uses for corporate mergers where there is no statutory deadline?
Benefits? Stimulating innovation and economic growth and bringing FCC into compliance with this neglected section of the Act.
On Moving the Upper Frontier of Commercial Spectrum Use
In the August 2012 issue of IEEE Wireless Communications is the above article by your blogger. The article starts
International spectrum allocations of the International Telecommunications Union (ITU) now go to an upper limit of 275 GHz. The upper limit of actual production commercial equipment appears to be in the 80 GHz range in the millimeterwaves or “mmW” region (30-300 GHz). While these upper frequencies have been often associated with fixed and satellite uses, the emergence of IEEE 802.11ad/WiGig mobile standards at 60 GHz and interest in broadband mobile applications above 100 GHz shows that many different uses may now be possible.
The initiation last year of the new IEEE Transactions on Terahertz Science and Technology shows that basic technology is moving on somewhat independent of lagging spectrum regulation. In addition, a technical highlight of the 2008 Beijing Olympics - ignored by the general press - was the use of 120 GHz point-to-point terrestrial links for high definition video distribution from venues to a central site and showed the potential for commercial spectrum use in presently virgin upper spectrum.
120 GHz Japanese system used at Beijing Olympics
Isn’t it time FCC start removing at >95 GHz such barriers to innovation and the necessary capital formation for it?
There are some valid issues of sharing these bands with existing passive allocations for radio astronomy and remote sensing as well as active federal government systems, but these make it more important that FCC give guidance to industry on how to commercialize these bands while protecting the other allocations. The nature of propagation at these bands as well as the ease at which narrow beam antennas can be used means that the concepts of spectrum regulation used at lower bands are not necessarily applicable and sharing is much more feasible.
IEEE-USA Harmful Interference White Paper
The document shown at right, a white paper entitled “Clarifying Harmful Interference Will Facilitate Wireless Innovation“, was released this week by IEEE-USA and was drafted by its Committee on Communications Policy. Here is the executive summary:
In recent years, many of the spectrum policy controversies in the United States have dealt with the basic issue of whether a proposed technology or service will cause “harmful interference” to existing spectrum users. Resolving these issues has typically taken several years in an era where technology is moving at “Internet speed.” As the Federal Communications Commission (FCC) discussed in its Wireless Innovation Inquiry, the delays and lack of transparency associated with making go/no go determinations on harmful interference may be discouraging private investment in the development of innovative wireless technology.
This White Paper reviews the background of what is harmful interference and suggests incremental ways in which the two spectrum management agencies in the United States, the FCC and the National Telecommunications and Information Administration (NTIA), could clarify the definition by giving guidance on the sub-problems associated with harmful interference determinations. Changing the definition is probably impractical, due to the long list of precedents over decades that have been built on the current definition, even though it is not established by statute.
The White Paper also suggests that establishing timeliness goals similar to those voluntarily created by the FCC for equally complex and voluminous merger and acquisition reviews could also address the disincentives for private capital formation in the wireless technology area. Such timeliness goals could create a more “level playing field,” with respect to other technical areas concerning private funding of technical development.
White House Advisory Committee Recommends Major Changes to Federal Spectrum Use
At its May 25th meeting the President’s Council of Advisors on Science and Technology, a White House advisory committee of top technical experts, endorsed a report from a subcommittee entitled “Realizing the Full Potential of Government-Held Spectrum to Spur Economic Growth”. The text of of the report has not been released to the public pending final editing and delivery to the President. However, there was a presentation at the PCAST meeting and below are two “slides” from the presentation.
The first slide to be discussed is below:
Its second point is to “state the policy of the U.S. government is to share underutilized spectrum”. It is pretty clear that that is not the present policy. I recall that during the drafting of the Spectrum Policy Task Force Report the NTIA staff had a temper tantrum on even mentioning that “interruptible spectrum” sharing of low average utilization federal spectrum might be considered. All reference to the topic in the context of federal spectrum was scribed from the report!
IRAC traditionalists will also not be very pleased with the 3rd point on sharing 1000 MHz with the private sector. I hope the report indicates that this can not be resolved by sharing 97-98 GHz!
Clay T. "Tom" Whitehead
The report recommends creating a “White House-based Spectrum Management Team” of senior Administration officials to work with NTIA. This would be a move in the right direction to give real Silicon Vally-style “adult supervision” to IRAC - the group that makes most spectrum management decisions without much accountability to anyone.
The report also recognizes the at present agencies have no incentive to cooperate with sharing and to be early adopters of sharing concepts. Thus it proposes to reward such early adopters in the budget process.
The report seems very promising and we look forward to seeing the actual text. Hopefully it won’t get lost in election year politics.
Spectrum Provisions in P.L. 112-96
On February 22 President Obama signed the Middle Class Tax Relief and Job Creation Act of 2012 (P.L. 112-96) into law. Despite its name, this 101 page bill is one of the more significant pieces of legislation in the spectrum area in several years.
While trying to solve the budget crisis and the economy, Congress could time to give gifts to its favorite industries. One provision that has attracted little attention is Section 6409 which Don Evans at CommLawBog describes as
a small measure of relief in the on-going struggle to get tower modifications approved and constructed. Buried in a collection of odds and ends dumped, seemingly as afterthoughts, at the end of the law, Section 6409 requires state and local governments to approve modifications of wireless towers and base stations as long as those modifications don’t substantially change the dimensions of the existing structures.
As Don points out, this section has little legislative history and deals with preemption issues that raise serious constitutional issues. Nevertheless, local zoning and permitting issues have slowed tower construction and put excess pressure on spectrum as the only solution. Of course, the cellular industry could have tried to hire engineers and architects to develop new tower designs more acceptable to neighbors, but in this case chose back room deals on Capitol Hill. I hope it works out well for them.
GAO is given some new temporary roles in the new legislation. In Section 6408 GAO is told “ to consider efforts to ensure that each transmission system is designed and operated so that reasonable use of adjacent spectrum does not excessively impair the functioning of such system.” This task is explicitly supposed to consider receiver standards, use of adjacent spectrum, and use of guardbands. Perhaps GAO will be able to address the issue of receiver standards that FCC and NTIA have been unable to deal with. In Section 6412 GAO is also told to study the rejection of FCC licenses in the 11, 18, and 23 GHz bands.
Sect 6201-6303 deal with first responder networks and hopefully will break the impasse in this area which has endangered public safety for decades.
Sect. 6403 has the TV incentive auction favored by CTIA and condemned by NAB, presumably with compromises to try to pacify both. The mysterious “unlicensed auction” has disappeared.
Sec. 6406 requires an NTIA study to determine if the U-NII band can be expanded to cover 5350–5470 MHz and 5850–5925 MHz .
Sect. 6601 and 6002 end the odd saga of the Telecommunications Development Fund which was created in the Telecommunications Act of 1996, 47 USC 614, to fund private sector telecom R&D projects with revenue that was a byproduct of FCC auctions. While perhaps a good idea, TDF was implemented badly with declining transparency. For example, search the FCC website for information on it and see how information has decreased over the years to almost no new information. TDF itself seems to be in a serious state of denial about where its funding came from - federal resources. The presence of an FCC-appointed board member at TDF has created serious appearances of conflict of interest and it is just as well that Congress is ending federal funding and granting in dependence to this group. Spectrum Bridge is a recipient of TDF funding and that creates an appearance that it gets unequal treatment from FCC.
Section 6701 expands the role of OMB in federal spectrum management which is a major improvement since the current legislation under which NTIA functions creates a basic conflict about whether NTIA is supposed to focus on the public interest in the needs of the federal spectrum users. There are created within NTIA 2 new entities: the “Technical Panel” and the Dispute Resolution Panel” to deal with federal spectrum relocation issues. Both panels have 3 members: one appointed by FCC, NTIA, and OMB. There is no requirement that they be federal employees, but there is also no pay for these positions. Guess what will happen? In any case, it is a move in the right direction.
Doug Sicker:
FCC -> NTIA
Douglas Sicker, Chief Technology Officer and Senior Advisor for Spectrum
Douglas Sicker is NTIA’s Chief Technology Officer and Senior Advisor for Spectrum. He is also an endowed professor in the Department of Computer Science at the University of Colorado at Boulder, with a joint appointment in the Interdisciplinary Telecommunications Program.
Dr. Sicker has held various positions in academia, industry, and government. Before joining NTIA, he was the Federal Communications Commission’s Chief Technologist. Previously, he served as a senior advisor on the FCC National Broadband Plan and, before that, as Director of Global Architecture at Level 3 Communications, Inc.
Earlier still, Dr. Sicker served as Chief of the FCC’s Network Technology Division. After leaving this agency, he served as Chair of the Network Reliability and Interoperability Council steering committee, an FCC federal advisory committee that focuses on network reliability, wireline spectral integrity and Internet peering and interconnection. He also served on the Technical Advisory Council of the FCC. In addition, he has also held faculty and industry positions in the field of medical sciences.
Dr. Sicker is a senior member of the IEEE, as well as a member of the ACM and the Internet Society. He has chaired and served on the program committees of numerous technical conferences including IEEE, DySPAN, ISART and TPRC. His research interests include network and wireless systems, network security, and telecommunications policy. He has research funded through the NSF, DARPA, the Internet Society and the Federal Aviation Administration. He holds a Ph.D. from the University of Pittsburgh. A full CV is available on his faculty page at the University of Colorado at Boulder.
Radar/Communications Spectrum Sharing: ISART 2011
On July 27-29 NTIA will host the 12th Annual International Symposium on Advanced Radio Technologies (ISART) at its Boulder, CO Institute for Telecommunications Sciences. The theme this year is “Developing Forward-Thinking Rules and Processes to Fully Exploit Spectrum Resources” with a special focus on radar bands.
For the third time since his retirement from FCC, NTIA was kind enough to invite your blogger to speak at this important meeting, but due to a conflicting family event, he is unable to attend. However, in view of the importance of this issue, he volunteered to produce a written paper on the topic to help stimulate discussion. Here is a link to that paper.
The paper starts by stating the need for new spectrum to speed economic growth which is important for both our society and for national security. Spectrum allocation should not be viewed as a zero sum game, but it is critical to develop innovative sharing techniques to get the maximum use of this limited resource. Since radar systems are a large user of spectrum and are difficult to share with using conventional approaches, this is a very timely conference.
TDWR
The main part of the paper advocates joint design of new radar systems with communications experts in order to maximize spectrum sharing and consider financial cost sharing of features that facilitate sharing subject to the radar mission needs. Just as the stealth bomber design involved a unique team of aeronautical engineers and EEs who could trade off flying issues with radar visibility issues, joint design of radar/comm systems may well result in sharing breakthroughs. While current legislation does not allow this type of cost sharing, it is not beyond the reach of new legislation that has been discussed. The paper points out that while full duplex paired spectrum with “24/7 and 1000 ms/ 1 s” time availability has been the norm for commercial systems, the decline of voice minutes and the domination of packetized traffic means that partial time availability, synched with radar rotation, could result in productive access to radar spectrum. While nonmilitary backlobe radio have not improved in 40+ years, advances in radio astronomy antennas indicate that new designs can significantly decrease backlobe levels and facilitate sharing. Such designs are expensive, but cost sharing could address that.
if you are interested, here, again, is the link.
New GAO Report on NTIA & Federal Spectrum Management
Here is GAO’s summary of what they found:
NTIA is responsible for governmentwide federal spectrum management, but its efforts in this area have been limited. In 2003, the President directed NTIA to develop plans identifying federal and national (both federal and nonfederal) spectrum needs, and in 2008, NTIA issued the federal plan. GAO found this plan has several limitations, does not identify governmentwide spectrum needs, and does not contain key elements and best practices of strategic planning. NTIA has yet to issue the national plan. Furthermore, NTIA’s primary spectrum management operations do not focus on governmentwide needs. Instead NTIA depends on agency self-evaluation of spectrum needs and focuses on interference mitigation, with limited emphasis on holistic spectrum management. Lacking a strategic vision, NTIA cannot ensure that spectrum is being used efficiently by federal agencies. Additionally, NTIA’s data management system is antiquated and lacks internal controls to ensure the accuracy of agency-reported data, making it unclear if decisions about federal spectrum use are based on reliable data. NTIA is developing a new data management system, but full implementation of the system is years away.
Federal agencies use spectrum for many purposes such as emergency communications and national defense, and NTIA requires the agencies to periodically evaluate their current and future spectrum needs. Agencies are supposed to ensure spectrum assignments fulfill established mission needs; however, NTIA does not have specific requirements for agencies to justify their spectrum assignments or validate data used for these evaluations. Consequently, NTIA has limited assurance that the data used to make spectrum management decisions are accurate. Federal agencies rely heavily on their program offices to obtain data for the required evaluations and often face challenges, such as resource constraints and staff turnover, when coordinating with field program staff. Given that validating spectrum assignments could require significant agency resources, it would be beneficial for NTIA to consider options for a different approach to obtain and validate critical spectrum assignment information from the agencies, such as requiring agencies to conduct site surveys or attest to the accuracy of data they submit.
In response to recent initiatives, NTIA has taken steps to identify spectrum that could be made available for broadband use. First, NTIA evaluated various spectrum bands and identified 115 megahertz of spectrum that could be made available for broadband within the next 5 years based on criteria it developed. Second, NTIA developed an initial plan and timetable for evaluating and repurposing additional spectrum for broadband use in 10 years. Affected federal agencies—that is, those agencies operating devices in the spectrum bands being evaluated—encountered difficulties providing NTIA with the necessary data and analyses during the most recent evaluation. For example, according to the affected agencies, they were required to analyze and submit a significant amount of detailed impact analyses that were not readily available. Agencies will likely continue to face challenges providing such analyses to NTIA in the future as NTIA begins evaluating a larger number of spectrum bands for possible broadband use in the next 10 years.
The basic problem is the first few words above - “NTIA is responsible for governmentwide federal spectrum management”. This is not reality under our current system. The Carter era approach of making NTIA give orders to much larger Executive Branch agencies about how to spend their own money and manage their own systems is just unrealistic in the Federal Government. In January, I quoted an FAA Federal Register document that stated that federal spectrum management is “an existing process involving several Federal agencies with an interest in spectrum use, which NTIA oversees under the Department of Commerce.” This is the reality of the present system. I believe that it will only change for the better when key players realize that the present charter of NTIA is unrealistic and move much of the President’s 47 USC 305 power back to the White House. Most of the NTIA staff can stay in Commerce as the “IRAC Secretariat” - which is what they really do. The key decision makers should be back in the White House where they were until 1978. In this case, oddly, Nixon got the organization right and Carter messed it up with well intentioned but ineffective change.
Interior Implements White House's Scientific Integrity Policy:How About FCC and NTIA?
Washington Post columnist Ed O’Keefe published an article today about the Department of Interior’s implementation of the White House’s scientific integrity policy which has been a recurring theme here.
This policy states
The public must be able to trust the science and scientific process informing public policy decisions. Political officials should not suppress or alter scientific or technological findings and conclusions. If scientific and technological information is developed and used by the Federal Government, it should ordinarily be made available to the public. To the extent permitted by law, there should be transparency in the preparation, identification, and use of scientific and technological information in policymaking. The selection of scientists and technology professionals for positions in the executive branch should be based on their scientific and technological knowledge, credentials, experience, and integrity.
Now, a lot of the FCC’s jurisdiction is nontechnical - think of the famous ‘wardrobe failure” - and even some of the technical jurisdiction in spectrum management involves trades between costs of new service with respect to technical impact on existing spectrum users and benefits of the new service. But in spectrum policy I am reminded of what a distinguished telecom lawyer once told me, “Some questions actually have (objective) answers”.
For example, as FCC and NTIA tool up for a battle over LightSquared’s ATC application, it will be very tempting for opponents of it to just say that it will cause GPS interference inevitably. Now a poorly designed MSS/ATC system in the band adjacent to the GPS L1 signal will clearly cause interference just as a poorly designed TDD AWS-3 system next an FDD AWS-2 system will cause interference. But the key policy issue is whether clever engineers can come up with a set of design details to reduce this interference to an acceptable level comparable to naturally occurring outages. This should be considered in the context of the above quote from the White House, not in smoke filled rooms without the potential for objective review of the analysis - unless it is necessary to keep certain details of the public record to protect properly classified information. But even in that case, FCC or NTIA could ask for an independent review by a contractor with clearances or could set up a technical advisory committee with cleared members similar to the Defense Science Board.
There is anecdotal evidence within FCC that the famous FleetCall waiver that allowed the creation of NEXTEL and the resulting 800 MHz interference to public safety was identified by the technical staff of WTB’s predecessor as having an interference risk and that the staff urged an explicit condition on the waiver. We now know what happened when the waiver was granted without this condition. Had a scientific integrity policy been in place at that time, the resulting public safety interference could have been resolved quickly.
So why don’t FCC and NTIA emulate the progressive move by Interior in implementing the President’s scientific integrity policy!
[Your blogger has no financial interest or relationship with LightSquared]
White House Announces
"Startup America":Maybe a Good Time for FCC to "Rediscover" Section 7 and Start Complying with it?
The White House announced today “Startup America”, “a plan for winning the future by out-innovating, out-educating, and out-building the rest of the world.”
President Obama said, “Entrepreneurs embody the promise of America: the belief that if you have a good idea and are willing to work hard and see it through, you can succeed in this country. And in fulfilling this promise, entrepreneurs also play a critical role in expanding our economy and creating jobs. That’s why we're launching Startup America, a national campaign to help win the future by knocking down barriers in the path of men and women in every corner of this country hoping to take a chance, follow a dream, and start a business.”
NTIA’s parent, the Department of Commerce seems fully committed to the program
The Department of Commerce will expand the i6 Challenge to help foster the commercialization of clean technologies, and are finalizing a plan to allow entrepreneurs to request faster review of their patents, an initiative that should lower patent pendency times overall and speed the deployment of new ideas to the marketplace.
No indication whether NTIA will be involved just as there is no indication whether NTIA will follow the President’s earlier guidance that “each agency shall ensure the objectivity of any scientific and technological information and processes used to support the agency's regulatory actions.”
Readers may recall that FCC’s long term apparent disinterest in compliance with Section 7 of the Communications Act of 1934, as amended, has been a recurrent theme here. By contrast, let’s see what Commerce’s Patent and Trademark Office is doing as part of the new program:
U.S. Patent & Trademark Office (USPTO) Gives Applicants Greater Control Over Examination Timing and Enables Fast-Track Examination Within 12 Months: The USPTO is pursuing an Enhanced Examination Timing Control Initiative (Three-track Examination) to give innovators more control over the application processing and support a more efficient market for innovation. Under this initiative, applicants would be able to request prioritized examination (Track I), obtain processing under the current procedure (Track II), or request a delay lasting up to 30 months (Track III). Entrepreneurs who are seeking capital, or accelerated market penetration, may benefit from the prioritized examination offered by the Track I option. In contrast, those entrepreneurs working to commercialize more embryonic ideas may prefer the extended timeframe associated with Track III. Another benefit to entrepreneurs will be shorter overall examination queues.
Section 7 is not a perfect piece of legislation. FCC has never implemented rules for administering it. FCC could ask Congress to amend it or even repeal it rather than just ignoring it. If anything, at present it is false hope for entrepreneurs and may discourage investment in entrepreneurial firms from VCs who get a cynical view of FCC’s treatment of startups in recent years.
But why don’t FCC and NTIA get on the President’s bandwagon and make life easier for wireless startups by promising decisions on some plausible schedule and real use of objective scientific information by NTIA in its presentations to FCC on shared spectrum - limited in public disclosure only by the need to protect properly classified information.
FAA Terminates Its "Spectrum Policy Grab" Rulemaking:
Highlights Fundamental Problem of NTIA Structural Weakness
Four years later, on July 21, 2010 the Federal Register published a Final Rule (R&O in FCC jargon) that goes into effect this week terminating this FAA rulemaking and taking no action at this time in the spectrum area. The NPRM proposed to require that anyone seeking a license or license modification in 13 different bands (some of which spanned more than one FCC allocation) must notify FAA independently of any FCC application. As the FHH CommLawBlog stated “the FAA lowered its conceit of attainable felicity a bunch, giving up on wide swaths of its 2006 proposal.”
The FAA, FCC and NTIA are collaborating on the best way to address this issue. A resolution of this issue is expected soon. Therefore, the proposals on FM broadcast service transmissions in the 88.0–107.9 MHz frequency band remain pending. The FAA will address the comments filed in this docket about the proposed frequency notice requirements and proposed EMI obstruction standards when a formal and collaborative decision is announced.
This problem has been around for at least 20 years and the FAA was so annoyed about perceived FCC and NTIA disinterest in their issues they made a successful end run around them and got some jurisdiction in this area in the Airport and Airway Safety and Capacity Expansion Act of 1987 (Pub. L. 100– 223 passed December 30, 1987) [FAA gave the legal background in p. 34030 of the NPRM, but they garbled the legal citations somewhat.]
Notwithstanding the about quote that “FAA, FCC and NTIA are collaborating” now, this whole incident shows US spectrum management policy at its worst. FCC and NTIA were both blindsided by the NPRM and it took 4 years to get any resolution, which in the end wasn’t much of a resolution. While NTIA thinks that it ”manages the Federal use of spectrum”, p. 42297 of the Final Rule states FAA’s viewpoint about “an existing process involving several Federal agencies with an interest in spectrum use, which NTIA oversees under the Department of Commerce.” So who is actually in charge?
The root cause of this problem is that FAA, which says it really cares about aviation safety where the other agencies don’t, also is caving in to pressure from the Aircraft Owners and Pilots Association (AOPA) - the “NRA” of the general aviation community. The ILS interference problems at the root of this issue are caused by “receiver-generated intermodulation” * in the ILS receiver when 2 or 3 strong FM broadcast signals are present that have a certain mathematical relationship to the ILS frequency. Both the receiver - regulated by FAA - and the FM broadcast stations are involved in the generation of the interference. Almost 20 years ago, ICAO developed receiver standards to minimize this problem.
Under pressure from AOPA, FAA has never made these ICAO receiver standards mandatory for all aircraft in the US. There is no indication that NTIA has ever pressured FAA on this issue.
NTIA has historically taken a hands off position to this problem even though NTIA claims it is responsible for “establishing and issuing policy regarding allocations and regulations governing the Federal spectrum use”. Historically, NTIA has been in favor of receiver standards for FCC-regulated services - but has been silent on other services where receiver problem impact FCC services.
So what is needed here is a real dialogue on how to split the burden of solving this problem between the FAA-regulated aircraft community and the FCC-regulated broadcast community with NTIA taken a forceful role in mediating a solution. However, the charter and legislation of NTIA dating back to the Carter Administration may make this impossible. The head of NTIA is an Assistant Secretary of Commerce and pragmatically assistant secretaries of smaller cabinet agencies do not tell other agencies how to spend their own money. This is the fundamental shortcoming of NTIA and results from its birth, not its present officials. Now many of us have observed the growth of the number of people in the Executive Office of the President with a strong interest in spectrum in the past 2 years. Hopefully this is a sign of the White House trying to exert some effective control over federal spectrum use which otherwise is mostly determined by user agency representatives meeting in secretive IRAC meetings. (They are so secretive, that I had trouble getting of minutes from a meeting that took place 25 years ago that I had attended!)
So FAA has backed off for now, but unless we get some real leadership in federal spectrum management this type of interagency problem will continue. Early in my FCC career, I both attended IRAC meetings from time to time and also represented the FCC at an interagency group on communications security (COMSEC). The Director, National Security Agency (DIRNSA in military jargon) has a national role in COMSEC that parallels NTIA’s role in spectrum policy. But the tone of the two meetings I attended was very different: DIRNSA sought the advice of federal agencies but made it clear that he was in charge and would consider the offered advice in making the final decision. By contrast, it was also clear at IRAC meeting that the various members were horse trading among themselves to decide what to tell NTIA to do. This is not leadership and spectrum is getting to be too precious to both the national economy and the national defense to base policy decisions on IRAC members horse trading among themselves for their own convenience. In Silicon Valley talk: “Adult supervision is desperately needed”.
I strongly believe that the White House needs a stronger role in spectrum policy even if it means partially undoing the creation of NTIA in 1977. I would transform the current NTIA Office of Spectrum Management into the IRAC Secretariat (which is a better description of most of its work at present) and leave most of the staff in Commerce while creating either a small decision making group in OMB or a new version of the old Office of Telecommunications Policy that reviews IRAC recommendations and has the resources to seek independent views of what is in the national interest, not the lowest common denominator of the IRAC membership.
----------
* Receiver-generated intermodulation is difficult to explain to people who are not radio techies because it is counter intuitive in many ways and can not be explained with simple analogies. It is the root cause of several complex spectrum policy issues in recent years such as the 800 MHz NEXTEL/public safety interference issue and the ongoing PCS H block controversy, WT Docket No. 04-356.
Your Blogger's Students Would Get a Failing Grade for a Statement Like This; Why is it in an NTIA/CSMAC Draft that has been Approved?
The above quote is from the draft of the NTIA Commerce Spectrum Management Advisory Committee’s Interference and Dynamic Spectrum Management Subcommittee that was approved “subject to edits” at the 7/27/10 CSMAC meeting in Boulder CO. It was also on p. 25 of the draft presented at the 5/10 meeting. (The final version of this report has not yet been posted on the CSMAC web site so more editing is possible before finalization.)
The CSMAC charter states that that the
“Committee will recommend approaches and strategies to ensure that the United States remains a leader in the introduction of new wireless technologies, while at the same time providing for the expansion of existing technologies and ensuring that the country’s homeland security, national defense, and other critical needs are satisfied.”
As we have written previously, the tone of the reports to date have focused on protecting incumbents from new entrants and putting as many burdens as possible on innovators. “Expanding new technologies” has not received much attention.
But the point of this posting is not the balance of power between incumbents and innovators. Some issues in spectrum management are subjective and reasonable people could disagree on these. Such issues include things like
- the priority of difference radio services,
- what is acceptable/harmful interference,
- what is the best propagation model for a given environment,
- minimum protection distances between systems,
- use of probabilistic interference models vice worst case (MCL) geometry, etc.
But as a prominent telecom lawyer once told me, “some problems actually have answers”. The quote above is one of those. The answer here is simple: the quote above is technical nonsense!
Your blogger has taught at George Washington U. and MIT and was recently appointed to the adjunct faculty at Virginia Tech. (More soon on the course he will teach there in the Spring Term.) Any student submitting such a statement in a term paper would fail the course.
A first clue that something is wrong can be found by just Googling “hybrid retry mechanism”, as shown below. (Bing could not find any use of this phrase either.)
Now for the ability of LTE and WiMAX to “ to operate at negative SNR” (signal-to-noise ratio) that is, where the desired signal is weaker than the background noise or interference - this is total nonsense that should be obvious to anyone who has studied communications theory in the past 30 years. LTE and WiMAX are both OFDM systems - as is the European DTV standard, DVB-T. WiMAX has several modulation schemes and picks the best one for a given location. Their performance as a function of SNR is shown below:
WiMAX bit error rate (BER) vs. signal-to-noise ratio (SNR)
All need positive SNR to meet the BER (bit error rate) target! This is not “rocket science”. This is stuff taught to undergraduate electrical engineering students (and probably should be on amateur radio tests if the testing were not controlled by Social Security recipients). If LTE and WiMAX could operated at negate SNR, wouldn’t you think that DVB-T, its technical cousin, could also? Therefore wouldn’t DVB-T be better than the US’ ATSC DTV? It really isn’t difficult to see how foolish this statement is.
Thee sentence in question was not an last minute addition to the 7/10 CSMAC draft. As stated above, it was also on p. 25 of the draft presented at the 5/10 meeting. So 2 months after this first draft was presented, the CSMAC approved the report “subject to edits” without any dissent within the committee. Does anyone read this stuff?
Your blogger has urged both FCC and NTIA to balance their advisory committee with technical people with significant peer recognition such as being IEEE fellows or members of the National Academy of Engineering. Clearly NTIA did not listen and this is an example of the result.
NTIA has to reappoint people to the CSMAC soon and FCC is still contemplating TAC nominations. Yes, the TV broadcasters and the major cellular carriers deserve a place at the table, but the price of admission should be sending someone who is technically competent in contemporary communications technology. Do we really need advisory committees made mostly of lobbyists with little or no technical background?
Spectrum policy is too important to be left mostly to lawyers.
[Note: I attempted twice to contact a senior technical staffer at MSTV,
the organization of subcommittee chairman Donovan and
“the recognized industry leader in broadcasting technology and spectrum policy
issues”, to ask about this sentence in the report.
Neither inquiry was returned.]
GNTEBHXBDBW2
The NTIA CSMAC Interference Report: An Embarrassment to the President's Spectrum Policies
For reasons discussed below this report is, or at least should be, a major embarrassment to NTIA as it is inconsistent with both the President’s spectrum policies and the charter of the committee. It both evades some major issues and pushes the parochial agendas of some committee members without trying to relate them to the broader public interests.
The White House has said
“(N)ew technologies have the potential to free up spectrum from many of its existing uses. In combination with regulatory changes, new and emerging technologies can facilitate the repackaging, reallocation, and even sharing of spectrum. Reallocating spectrum to its most valuable use promises to be a win-win effort – creating value that not only spurs new innovations and creates new jobs, but also benefits existing spectrum users by allowing them to raise funds for transformative new investments.
This CSMAC report repeatedly takes a negative view towards all innovation and an absolute priority on protecting incumbents. For example on p. 7 it says, “If an incumbent service makes changes to its system’s architecture or modulation technique that results in new interference, then the spectrum to be used to establish any guardband protections should be provided by the service making such changes.” So no matter how outdated an incumbent’s equipment is, no matter how inefficiently an incumbent uses spectrum, no matter how lightly loaded an incumbent’s band is, the burden of protecting the incumbent always falls entirely on the new comer in the mind of CSMAC - which just happens to be dominated by incumbents.
Much of the report echoes the broadcast industry’s view on the database approach to TV whitespace, Docket 04-186. Perhaps not surprising since MSTV’s David Donovan, a lawyer, chaired this group. In private discussions, many CSMAC members observed that much of the long database discussion in the report was aimed at the FCC rulemaking and was irrelevant to the NTIA issues.
One might think that the “Interference Subcommittee” might spend some effort discussing what is “interference”? They dismiss this topic quickly:“Because of the different policy concerns, the Subcommittee makes no judgment as to the appropriate definition of interference that would trigger legal action. Accordingly, we use the term “interference’ in its generic sense.” (p.16)
Hey guys, maybe defining interference in detail is beyond your scope, but how about a few words on whether the current 47 CFR 2.1 definition is workable? What about the FCC view in the Wireless Innovation NOI:
“The viability of spectrum access for new radio services often centers on whether the new service may cause harmful interference to incumbent services. This can lead to delays through protracted rule making proceedings that can create uncertainty and discourage investment. Are there ways the Commission can improve upon this process?” (para. 34)
Does this issue apply to NTIA processes also? Are NTIA harmful interference determinations any faster or more transparent than FCC ones? Will sharing of Government spectrum by technical innovators be that much more attractive than allocations in NG spectrum? CSMAC - the world wonders?
The report was not content at sniping at the TV WSD intruders, it appears Mr. Donovan gave “professional courtesy” to his peers in the cellular establishment since cellular carriers and their allies were also well represented amount the committee members. Thus the report also took a cheap shot at the AWS-3 proceeding saying
•There is widespread consensus on the mechanisms and dangers of creating interference when licensing services that employ different duplexing technologies in adjacent spectrum.
•Industry stakeholders recently demonstrated the risks associated with plans to permit TDD operations in AWS-3 spectrum, without adequate allowances to protect adjacent AWS-1 FDD operations. (emphasis added)
Note the use of the word “stakeholders” here rather than “incumbents”. Don’t the stakeholders in FCC proceedings include also the public who could benefit from new service and the advocates of new service? The use of “stakeholders” in the report draft clearly shows the consistent bias in favor of incumbents. In any case, the demonstration was that referred to is controversial and the issue has not been resolved by FCC almost 2 years later.
Does the Interference Committee have any views at all on whether intersystem interference should be judged always on worst case/“minimum coupling loss” geometry or whether in some circumstances stochastic/probabilistic modeling should be used as it is from time to time in CEPT and ITU studies?
Filters have a big impact on all types of interference other than cochannel interference. Does the committee have any thoughts on whether filters are getting better and how that might impact sharing and guardbands?
Many types of wireless equipment now have a service life of a few years. Should this be taken into account in sharing and guardband determinations as the major cellular carriers have argued that PCS H block entrants can use increased power after existing handsets are replaced with newer models with better intermodulation immunity?
Finally, since this is a report on both interference and DSA, shouldn’t it at least mention the observation of Preston Marshall, formerly of DARPA, that cognitive radios could be designed to select not just idle frequencies but idle frequencies that will not cause interference to receivers with limited interference rejection capabilities that are nearby in frequency and space ?
John Muleta, former Chief of FCC/WTB, and I wrote a statement on this for the CSMAC that received little interest at the meeting in the rush to approve the flawed report. Readers might want to compare it with the report draft and draw their own conclusions. Please tell us what you think.
We will post a link to the final version of the report when it is released.
[MSS has done work for M2Z Networks and Adaptrum, Inc., but this post is not part of that work and is solely the view of MSS.]
(Does not include readers using RSS feeds.)
![[Valid RSS]](valid-rss-rogers.png "Validate my RSS feed")
