Depending how this is implemented, it could effectively legalize "old"
interference, and place the onus on the receiver to work around noise not
in excess of what exists when the level is measured for regulatory
purposes. On the other hand, that level might well be lower than what Part
15 now allows, which level we are fining out the hard way is far from
protective of many radio services. I can see a problems with noise
temperature from a regulatory standpoint already, as Part 15 testing would
never be the same, with different limits for different places and
frequencies.
The NPRM proposes to initially apply the new method in two non-Amateur
bands:
"... we propose to apply the new interference temperature approach
described herein to unlicensed operation within the fixed (FS) and fixed
satellite service (FSS) uplink band at 6525-6700 MHz and the FS, FSS, and
BAS/CARS band at 12.75-13.25 GHz
(excluding 13.15-13.2125 GHz). These bands were chosen because we believe
they offer the possibility to implement in a simplified way the
interference temperature concept and approach. We seek comment on the
appropriateness of these bands and whether additional frequency bands could
be suitable for testing the concept of interference temperature."
It may be worthwhile at this time to Comment that this NPRM should not
create Noise Temperature interference standards or authority for any OTHER
bands.
NPRM: http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-289A1.pdf
Cortland KA5S
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