[RFI] ARLB025 FCC Seeks Comments on Technological Advisory Council Recommendations

[Dave Cole (NK7Z)]

So far you and I are on teh same track here...  I did not take this as a 
good thing for hams...  It looks to me, as if the FCC is getting ready 
to due away with the, if it interferes it needs to stop rules...  I hope 
I am wrong in this.

73s and thanks,
Dave
NK7Z
http://www.nk7z.net

On 12/05/2017 06:31 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 at 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 at www.arrl.org>
> To: dave at 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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