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Wireless Innovation and Interference

Here is my statement from the November 12 seminar
The Unfinished Radio Revolution:
New Approaches to Handling Wireless Interference

cosponsored by Silicon-Flatirons, IEEE-USA, CTIA, New America Foundation, and FCBA.

Innovative wireless communications is important not just for wireless operators and manufacturers, but also for firms in other industries that depend on the latest technology for improving their productivity and for new non-telecom firms such as Amazon, E-bay, Netflix that are enabled by cutting edge technology. It is key to the health of the US economy.

Most other industrialized nations use a state capitalism form of spectrum management and wireless industrial policy that uses Soviet-style economic planning

In contrast, since late 1970s FCC spectrum policy has focused on technical deregulation and market forces to stimulate innovation and growth. This year is the 25th anniversary of both Qualcomm’s founding and the regulatory basis for Wi-Fi and Bluetooth – all products of this deregulatory ferment.

Spectrum deregulation has a core goal of interference prevention:

  • Assuring incumbents of realistic expectations so as to stimulate their investment AND

  • Assuring innovators and entrepreneurs a transparent and timely red light/green light system for determining if innovative systems will cause “harmful interference”

FCC got it right in the Wireless Innovation NOI when it said

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.

In the Northpoint/MVDDS, UWB, and AWS-3 proceedings we saw deliberations of harmful interference that not only violated the timeliness requirement of Section 7 of the Act but were totally inconsistent with
any plausible business plan of a startup entrepreneur. Today’s capital markets make investments for such innovative technology almost impossible due to the excessive regulatory risk resulting from FCC’s slow deliberations.

Qualcomm got its key regulatory decision for CDMA 2 years after its founding. Such decisiveness in innovative spectrum policy is impossible today
ectrum policy determination by fiscal exsanguination of entrepreneurs is both ineffective and inconsistent with our form of government.

If we can’t get spectrum deregulation and interference policy correct, the USA might be better off just joining CEPT and taking an active role in their spectrum management system - based on Soviet style economic planning.

Basic technical Issues in defining radio rights or interference

Receiver Standards
Explicitly stated expectations for adjacent channel rejection and intermodulation vulnerability, e.g. 3rd order intercept point, are urgently needed for each radio service in order to resolve harmful interference issues in a timely way. These standards should not be mandatory - which is just as well since FCC in general does not have such jurisdiction at present.

I/S Protection at Receiver
Made simpler by digital convergence. In most cases I/S of - 6
to -10 db is adequate, former mixed analog environment was more complex. However, CDMA systems have more complex concerns since interference translates into capacity. But environment noise levels set a natural baseline

I/S Field Strength at the Antenna vice I/S Power at the Receive
MIMO technology is increasingly practical so in many cases some rejection by antennas should be considered

Propagation Models
Much of the controversy over TV white space results from the use of a 1966 precomputer age propagation model that FCC itself has said has severe limitations in its applicability. While propagation is an esoteric field, inappropriate models can warp any spectrum rights regime

MCL vice Stochastic Modeling
Incumbents prefer that the worst case MCL (minimum coupling loss) scenario is decisional. While FCC has a limited record of using stochastic modeling , both FCC and NTIA have no clear policy in this key area. However, in Europe, stochastic modeling is often used

Acceptable Interference Statistics

How much interference is acceptable? In the MVDDS decision FCC used naturally occurring rain outages as a baseline and decided to accept a 10% theoretical increase – something not noticeable in practice. FCC and NTIA should consider the general issue that naturally occurring outages in space and time should be considered as a reference point although the allowed increased should be determined on a case by case basis

Who should make detailed spectrum rights proposal for public consideration?

It is key that FCC and NTIA work in parallel here to develop consistent policies

Doubtful that present FCC or NTIA can develop a level playing field interference protection scheme that deals with both incumbents and new entrants fairly
In the 1970s, FCC - like other federal regulatory agencies with key long term technical policy dilemmas - asked National Academy of Sciences/National Research Council to propose regulatory framework for what later became Parts 25 and 68 – at the time exceedingly controversial issues opposed by powerful interests. The resulting C band terrestrial/satellite sharing and telephone interconnection resulted in tremendous economic growth and were emulated all over the world.

FCC and NTIA should consider asking NAS/NRC to repeat its past role – and the role it regularly plays for other agencies – to draft a specific framework for determining interference rights that balances all interests. It will never be an objective definition, but a framework that speeds up the present process will increase certainty for BOTH incumbents and innovators.

Your blogger’s detailed paper on this topic
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