Dave and Roger,Noise "In the public interest" is also balanced by the needs of
the telecommunications carriers, so if the power, or any utility causes
problems, then that will require some attention to mitigate. That would
likely address the issues for broadcast radio/TV users, cell users, and yes,
Amateur Radio operators. We need to offer refinements in process and standards
that are workable and economically sound.73,Gordon Beattie, W2TTT 201.314.6964
Sent via the Samsung Galaxy Tab S2, an AT&T 4G LTE tablet
-------- Original message --------From: "Dave Cole (NK7Z)" <dave@nk7z.net>
Date: 12/6/17 02:07 (GMT-05:00) To: rfi@contesting.com Subject: Re: [RFI]
ARLB025 FCC Seeks Comments on Technological Advisory
Council Recommendations
How best should we respond to the comments which are being sought? That
is the main question as I see it...
Lets leave off the infighting about the ARRL etc. and focus on the
actual issue here... The FCC is considering changes to the existing RFI
rules, which right now favor us, if only they were enforced with more
vigor.
At this point, I don't really see anything dealing with actual RFI most
Amateur Operators are putting up with... i.e. Grow lights, SMPS, and
such...
One thing that scares hell out of me, is in this new interpretation-- if
say, the power company, is causing an issue, it might be that that it is
OK, (read that as "In the public interest"), to interfere just a bit
with Amateur Radio. This could apply to street lights, BPL, or anything
that could be construed to be "in the public interest"...
If that is true, then that is a very bad precedent to allow being set.
We need to fully understand this request, and all of us need to submit
well thought out input to the FCC...
More discussion is needed here before responses are submitted...
73s and thanks,
Dave
NK7Z
http://www.nk7z.net
On 12/05/2017 10:08 PM, Roger (K8RI) wrote:
> I see two parts that pose a "potential" risk to ham radio and it mainly
> depends on how those sections are interpreted and applied.
> Historically interference signals have been measured and held to a
> standard. IE Quantitative. If measured on a comparative basis, we could
> lose a lot, or we could gain a lot. It "depends" on how the relevance of
> each service is defined rather than signal strength. Remember, Amateur
> Radio is a "Service" as defined by the FCC
>
> Quantitative is to be replaced with the inferred/relative importance of
> the services involved. Will there be an established hierarchy of
> services? If so, who determines the importance of one service over
> another? Will it become the domain of local officials? If so, Ham
> Radio in some areas would be considered no more than a hobby, rather
> than a service as it is defined by the regulations. "Here", in this area
> "I believe" it would be considered close to Emergency services as The
> county EOC has a Ham Station set up that is maned during emergencies,
> Hams are involved with searches of many sorts.
>
> SO FAR as the proposal is stated in the bulletin there are just too
> many unknowns and interpretations undefined. This may be a technical
> approach, but I fear the power of politics can/may have on defining the
> relevance of the services. They refer to adjacent services and that
> brings to mind a company called LightSquare. Had that not been squashed
> it had dire ramifications for the future of frequency allocations.
>
> Do I trust the FCC to do the right thing? Welll, you only need to do
> search on the "FCC and LightSquared Scandal". The FCC gave LightSquared
> (A major contributor to that administration) It was even called
> "Another Solyndra?"). The first link that search string brings up is
> https://www.forbes.com/sites/fredcampbell/2015/08/31/fccs-lightsquared-scandal-another-solyndra-in-the-making/#7767397d5e69
>
> The FCC violated their own rules. I was a pilot at the time so I was
> quite interested in this and did a lot of letter writing.
>
> A quote from that Forbes article "Solyndra pales in comparison to what’s
> at stake with LightSquared, another shaky company that went bankrupt
> after betting on billions of dollars in government benefits
> <http://www.forbes.com/sites/danielfisher/2012/05/01/whats-falcones-3-billion-gamble-on-lightsquared-worth-now/>.
>
> The Federal Communications Commission (FCC) initially doled out
> government benefits to LightSquared in 2010, when a trio of agency
> bureau chiefs
> <https://apps.fcc.gov/edocs_public/attachmatch/DA-10-535A1.pdf>
> illegally granted LightSquared a nationwide cellular license
> <https://apps.fcc.gov/edocs_public/attachmatch/DA-10-534A1.pdf> in a
> spectrum band allocated for satellite communications."
>
> Because of things like this that proposals like this one with loosely
> defined parameters make me very uneasy. Past administrations have held
> great sway with departments and I'm referring to many more than the
> previous one.
>
> 73, Roger (K8RI)
>
>
> On 12/5/2017 Tuesday 9:31 PM, Ed K0iL wrote:
>> Dave & group,
>>
>> This one could be a negative for HF ham bands or any band for that
>> matter:
>> " More broadly adopt risk-informed interference assessment and
>> statistical
>> service rules. 'In judging whether to allow new radio service rules,
>> the TAC
>> observes that the Commission has to balance the interests of
>> incumbents, new
>> entrants, and the public,' the Public Notice explained. 'The process of
>> analyzing the tradeoffs between the benefits of a new service and the
>> risks
>> to incumbents has, to date, been essentially qualitative.' "
>>
>> Key here is the phrases here:
>> ..."risk-informed interference assessment..." Wondering how they define
>> risk-informed? Me to. There's a link to another page to define it.
>> ..."has to balance the interests of incumbents (i.e. hams), new entrants
>> (i.e. new devices, IoT, etc), and the public (i.e. balance weight of
>> public
>> vs. hams). We lose.
>>
>> This one is more blunt:
>> "... radio services should expect occasional service degradation or
>> interruption." Wonder why they didn't use this on TVI back in the 50s
>> thru
>> 70s when they shut down hams due to cheap TV receivers? Oh, that's
>> right,
>> "balance of weight of public vs. ham"
>>
>> The whole reason this was initiated was to "address the increasing
>> challenges pf efficient and fair SPECTRUM ALLOCATION"..., and of
>> "finding a
>> balance between the rights and responsibilities of transmitters AND
>> RECIEVERS." Anyone else a little nervous yet?
>>
>> Guess I should read the whole pdf on the link a little slower this time.
>> At least they'll start small and not do a major overhaul this topic in
>> regs.
>>
>>
>> 73, de ed -K0iL
>>
>> -----Original Message-----
>> From: RFI [mailto:rfi-bounces@contesting.com] On Behalf Of Dave Cole
>> (NK7Z)
>> Sent: Tuesday, December 05, 2017 2:56 PM
>> To: RFI Mail list at contesting.com
>> Subject: [RFI] ARLB025 FCC Seeks Comments on Technological Advisory
>> Council
>> Recommendations
>>
>> -------- Forwarded Message --------
>> Subject: ARLB025 FCC Seeks Comments on Technological Advisory Council
>> Recommendations
>> Date: Tue, 5 Dec 2017 15:42:51 -0500 (EST)
>> From: ARRL Web site <memberlist@www.arrl.org>
>> To: dave@nk7z.net
>>
>> SB QST @ ARL $ARLB025
>> ARLB025 FCC Seeks Comments on Technological Advisory Council
>> Recommendations
>>
>> ZCZC AG25
>> QST de W1AW ARRL Bulletin 25 ARLB025
>> From ARRL Headquarters Newington CT December 5, 2017 To all radio
>> amateurs SB QST ARL ARLB025
>> ARLB025 FCC Seeks Comments on Technological Advisory Council
>> Recommendations
>>
>> In a Public Notice released on December 1, the FCC's Office of
>> Engineering
>> and Technology (OET) has invited comments by January 31, 2018, on a
>> wide-ranging series of Technological Advisory Council
>> (TAC) recommendations that, if implemented, could alter the spectrum
>> policy
>> regulatory landscape - especially with respect to interference resolution
>> and enforcement. An advisory body, the TAC's membership includes several
>> Amateur Radio licensees. ARRL will file comments in the proceeding, ET
>> Docket 17-340.
>>
>> The Public Notice is in PDF format on the web at,
>> http://transition.fcc.gov/Daily_Releases/Daily_Business/2017/db1201/DA-17-11
>>
>> 65A1.pdf
>> .
>>
>> The TAC has called on the FCC to:
>>
>> * Consider adopting the spectrum management principles spelled out in the
>> Council's Basic Spectrum Principles white papers of March
>> 2014 and December 2015, and "set clear expectations about the affected
>> system's capabilities regarding interference, such as harm claim
>> thresholds."
>>
>> * More broadly adopt risk-informed interference assessment and
>> statistical
>> service rules. "In judging whether to allow new radio service rules,
>> the TAC
>> observes that the Commission has to balance the interests of
>> incumbents, new
>> entrants, and the public," the Public Notice explained. "The process of
>> analyzing the tradeoffs between the benefits of a new service and the
>> risks
>> to incumbents has, to date, been essentially qualitative."
>>
>> * Implement "a next-generation architecture" to resolve interference, and
>> establish a public database of past radio-related enforcement activities.
>> The TAC also recommended that the FCC "incorporate interference
>> hunters in
>> the [interference] resolution process."
>>
>> The TAC spelled out a set of three "Interference Realities," which, in
>> part,
>> assert that harmful interference "is affected by the characteristics
>> of both
>> a transmitting service and a nearby receiving service in frequency,
>> space,
>> or time," and that radio services should expect occasional service
>> degradation or interruption."
>>
>> The TAC also posed three "Responsibilities of [Radio] Services that, in
>> part, state that "receivers are responsible for mitigating interference
>> outside their assigned channels" and that "transmitters are
>> responsible for
>> minimizing the amount of their transmitted energy that appears outside
>> their
>> assigned frequencies and licensed areas." The TAC acknowledged that
>> the FCC,
>> by and large, does not regulate receiving systems.
>>
>> Another three principles under "Regulatory Requirements and Actions"
>> the TAC suggested that the FCC may "apply interference limits to quantify
>> rights of protection from harmful interference." According to the Public
>> Notice, the TAC "has recommended interference limits as a method for the
>> Commission to communicate the limits of protection to which systems are
>> entitled, without mandating receiver performance specifications." The TAC
>> called for a "quantitative analysis of interactions between services"
>> before
>> the FCC could "make decisions regarding levels of protection," The OET
>> said.
>>
>> "[T]he TAC believes the principles can be applied to all systems and
>> result
>> in an optimal solution for each service," the Public Notice said. The TAC
>> has suggested that the FCC not base its rules on exceptional events and
>> worst-case scenarios but on reality.
>>
>> "The TAC recommends that the Commission start soon, and start small,
>> and not
>> attempt a major overhaul of its regulatory approach," the Public Notice
>> said.
>> NNNN
>> /EX
>> _______________________________________________
>> RFI mailing list
>> RFI@contesting.com
>> http://lists.contesting.com/mailman/listinfo/rfi
>>
>> _______________________________________________
>> RFI mailing list
>> RFI@contesting.com
>> http://lists.contesting.com/mailman/listinfo/rfi
>>
>
_______________________________________________
RFI mailing list
RFI@contesting.com
http://lists.contesting.com/mailman/listinfo/rfi
_______________________________________________
RFI mailing list
RFI@contesting.com
http://lists.contesting.com/mailman/listinfo/rfi
|