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
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