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

Wed Dec 6 01:08:37 EST 2017

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 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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-- 
Roger (K8RI)

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