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.]
![[Valid RSS]](valid-rss-rogers.png "Validate my RSS feed")
