Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of )
)
Interference Immunity Performance ) ET Docket No. 03-65
Specifications for Radio Receivers )
)
Review of the Commission’s Rules and ) MM Docket No. 00-39
Policies Affecting the Conversion to Digital )
Television )
COMMENTS OF THE NATIONAL TELECOMMUNICATIONS
AND INFORMATION ADMINISTRATION
Michael D. Gallagher Kathy Smith
Acting Assistant Secretary for Chief Counsel
Communications and Information
Fredrick R. Wentland National Telecommunications and
Associate Administrator Information Administration
Office of Spectrum Management U.S. Department of Commerce
1401 Constitution Avenue, N.W.
Bernard Joiner Room 4713
Electronics Engineer Washington, DC 20230
Office of Spectrum Management (202) 482-1816
November 12, 2003
Table of Contents
EXECUTIVE SUMMARY...............................................................................................................
I. BACKGROUND....................................................................................................................
II. NTIA APPLAUDS THE COMMISSION FOR BEGINNING TO CONSIDER THE ADOPTION OF RECEIVER INTERFERENCE IMMUNITY STANDARDS TO REDUCE INTERFERENCE AND INCREASE SPECTRUM EFFICIENCY....................................................................................................
III. NTIA URGES THE COMMISSION TO INITIATE A RULEMKAING TO ADOPT APPROPRIATE INDUSTRY-DEVELOPED VOLUNTARY STANDARDS...................................................
IV. MANY RECENT INSTANCES OF INTERFERENCE COULD HAVE BEEN PREVENTED BY RECEIVER STANDARDS.........................................................................................................................
V. ADOPTION OF RECEIVER STANDARDS WILL PERMIT MORE EFFICIENT USE OF THE RADIO FREQUENCY SPECTRUM...................................................................................................
VI. NTIA RECOMMENDS THAT THE COMMISSION GIVE FIRST PRIORITY TO ADOPTING STANDARDS FOR NEW ALLOCATIONS..................................................................................................
VII. NTIA SUPPORTS THE COMMISSION'S FLEXIBLE APPROACH TO ADOPTING RECEIVER STANDARDS.........................................................................................................................
VIII. CONCLUSION......................................................................................................................
RECEIVER SPECTRUM STANDARDS, PHASE I - SUMMARY OF RESEARCH INTO EXISTING STANDARDS, NTIA REPORT 03-404.......................................................................................... Appendix A
EXECUTIVE SUMMARY
The National Telecommunications and Information Administration (NTIA) supports the Federal Communications Commission (Commission) in its efforts to consider the adoption of interference immunity performance specifications for non-government radio receivers. NTIA has adopted immunity standards for federal receivers in its Manual of Regulations and Procedures for Federal Radio Frequency Management. These standards cover a large percentage of federal operations. NTIA believes these standards have done much to prevent interference to federal users of the spectrum. They have also permitted NTIA to utilize the spectrum more efficiently by providing minimum performance levels that can be assumed in service planning and frequency coordination processes.
NTIA urges the Commission to initiate a proceeding to consider appropriate interference immunity performance standards for the private sector as well. NTIA has seen instances where interference problems have occurred due to a lack of receiver immunity to non-cochannel signals and believes that incorporating receiver standards will eliminate many of these problems. NTIA also believes that the implementation of receiver standards will permit more effective management of spectrum resources as they will permit reliable predictions of the effect of new transmitters on non-cochannel receivers in the environment. By enabling tighter packing of assignments in a particular band, standards may also facilitate more efficient use of the spectrum.
NTIA also recommends that the Commission give priority to recently allocated or reallocated bands, especially those reallocated from the federal government, before these bands become filled with receivers not conforming to any standards.
NTIA concurs with the Commission’s approach of considering various frameworks for standards, including voluntary or mandatory, service specific or generic, and equipment standards or environmental reports. The approach selected by the Commission should be effective, yet flexible and impose a minimum of hardship and costs on the users of the spectrum.
NTIA has recently completed the first phase of a study on receiver spectrum standards and has published NTIA Report 03-404, Receiver Spectrum Standards, Phase 1, Summary of Research into Existing Standards. By including the NTIA Report as part of these comments, NTIA hopes to draw attention to the extensive work already performed in the area of receiver standards by the various industry organizations. These organizations have already developed voluntary standards that have proven very successful and NTIA urges the Commission to rely on them to the extent appropriate.
COMMENTS OF THE NATIONAL TELECOMMUNICATIONS
AND INFORMATION ADMINISTRATION
The National Telecommunications and Information Administration (NTIA), an Executive Branch agency within the Department of Commerce, is the President’s principal adviser on domestic and international telecommunications policy, including policies relating to the nation’s economic and technological advancement in telecommunications. Accordingly, NTIA makes recommendations regarding telecommunications policies and presents Executive Branch views on telecommunications matters to the Congress, the Federal Communications Commission (Commission), and the public. NTIA, through the Office of Spectrum Management, is also responsible for managing the federal government’s use of the radio frequency spectrum. NTIA respectfully submits the following comments in response to the Commission’s Notice of Inquiry in the above-captioned proceeding.[1]
I. BACKGROUND
The Spectrum Policy Task Force recommended that the Commission consider applying receiver performance requirements, and that a Notice of Inquiry (NOI) be pursued as part of this effort.[2] The Commission responded with the present NOI which requests comments on the following areas: current receiver environment; performance and standards; possibilities of improving receiver immunity; potential impact of receiver standards; possible approaches to achieving desired levels of performance; considerations that should guide the Commission’s approach; and issues relating to the possible incorporation of receiver immunity performance incentives, guidelines, or standards.
II. NTIA APPLAUDS THE COMMISSION FOR BEGINNING TO CONSIDER THE ADOPTION OF RECEIVER INTERFERENCE IMMUNITY STANDARDS TO REDUCE INTERFERENCE AND INCREASE SPECTRUM EFFICIENCY.
For many years, NTIA has imposed receiver immunity standards on the federal sector through its Manual of Regulations and Procedures for Federal Radio Frequency Management.[3] A large percentage of the current federal frequency assignments are subject to mandatory receiver spectrum standards.[4] NTIA believes the adoption of receiver immunity standards has greatly minimized interference to federal systems. NTIA believes the adoption of receiver spectrum standards will result in a significant reduction in instances of interference and permit a notable increase in the efficiency of the use of the radio spectrum.
The Commission has established transmitter parameters (e.g., transmit power and emission characteristics) in given portions of the spectrum in which the nature of radio signals is well understood and generally predictable by equipment manufacturers and licensees. In the absence of receiver immunity standards, the Commission has had to assume levels of receiver performance as a basis for certain existing rules.[5] Likewise, in selecting frequency assignments, public system operators and frequency coordinators must assume receiver immunity performance levels in many cases. Such assumptions may either risk interference or foster inefficient use of the spectrum. The Commission notes that the dramatic increases in the overall demand for spectrum-based services, rapid technical advances in radio systems, and the need for increased access to the limited spectrum resource in recent years are straining the effectiveness of the Commission’s longstanding spectrum policies. These changes have prompted the Commission to provide incentives for users to migrate to more efficient uses of the spectrum.[6] NTIA believes that this migration can be facilitated by specifying both transmitter and receiver standards.
NTIA has recently published the first phase of a study on receiver standards, NTIA Report No. 03-404. A copy of this report is provided in Appendix A to these comments and NTIA urges the Commission to consider it in its decisions. As discussed in this report, NTIA has mandatory receiver spectrum standards for most federal users of the radio spectrum. NTIA has taken the approach that the performance of both the transmitter and the receiver should be regulated. This approach to management of the radio spectrum emphasizes prevention of interference and spectrum use efficiency. Some federal agencies implement even stricter standards.[7] Therefore, these standards do not prevent users from moving to more efficient technologies or better receiver performance than required, but they establish a baseline.
NTIA offers the following comments to specific issues raised in the NOI.
III. NTIA URGES THE COMMISSION TO INITIATE A RULEMAKING TO ADOPT APPROPRIATE INDUSTRY-DEVELOPED VOLUNTARY STANDARDS.
In its study of receiver standards, NTIA has observed that there are many existing standards developed by US and international industry associations.[8] Adherence to these standards has done much to lessen the likelihood of interference for many services. NTIA recommends that the Commission initiate a proceeding to adopt these standards on a voluntary or recommended basis. These standards have been devised by industry representatives who are familiar with the various services and what is economically feasible. These standards bodies include among others, the Telecommunications Industry Association (TIA), the Consumer Electronics Association (CEA), the Radio Technical Commission for Aeronautics (RTCA), the International Telecommunications Union (ITU), the International Civil Aviation Organization (ICAO), the European Telecommunication Standard Institute (ETSI), and the International Electrotechnical Committee (IEC).[9] To maintain a cooperative relationship with those organizations managing voluntary standards and to draw on their expertise, NTIA concurs with the Commission’s recommendations that these organizations be deeply involved in the standards process.[10]
IV. MANY RECENT INSTANCES OF INTERFERENCE COULD HAVE BEEN PREVENTED BY RECEIVER STANDARDS.
NTIA believes that receiver designs that do not take into account their operational environment are often vulnerable to interference from non-cochannel signals because of inadequate selectivity or other unwanted signal suppression provisions. NTIA has investigated a number of instances of reported interference that could have been avoided if appropriate receiver standards had been applied. Some examples enumerated in NTIA Report 03-404 include the following: commercial fixed-satellite service receiving earth stations that use low noise amplifiers at the antenna and have little or no filtering prior to active components,[11] commercial digital radio relay receivers which use low noise amplifiers with little or no filtering prior to active components,[12] consumer unlicensed Part 15 receivers such as garage door openers which use very wide bandwidths,[13] analog television and other consumer receivers with generally very poor Radio Frequency selectivity,[14] commercial Very High Frequency (VHF) Maritime receivers with insufficient selectivity resulting in interference from National Oceanic and Atmospheric Administration (NOAA) weather broadcasts and land mobile transmitters.[15] Another example not mentioned in the report are wireless cable system receivers with insufficient selectivity resulting in interference from Air Traffic Control radars in the 2700 to 2900 MHz band.[16]
V. ADOPTION OF RECEIVER STANDARDS WILL PERMIT MORE EFFICIENT USE OF THE RADIO FREQUENCY SPECTRUM.
The lack of receiver spectrum standards makes the determination of potential interference and frequency assignment practices difficult. Receiver performance is often characterized by assumptions or manufacturers specifications, and the latter may not be available. This prevents the efficient assignment of frequencies, as there is no sure way to assess the susceptibility of receivers to new transmitters placed in their environment.
As the Commission states in the NOI, receiver improvements could also provide greater opportunities for access to the spectrum.[17] The Commission further states that improving the general level of receiver performance with respect to interference immunity would allow increased operation of radio services on adjacent channels and frequency bands and thereby promote spectrum sharing and radio system interoperability that would permit more efficient use of the spectrum.[18] NTIA concurs with the Commission in that the increased demands placed on the radio spectrum can be accommodated through greater spectrum utilization efficiency. Currently adjacent or semi-adjacent channels cannot be assigned in the same or nearby areas in some services. This results in many potential assignments being unavailable. One well-known example is the practice not to assign adjacent analog television channels in the same area due to poor receiver selectivity. As stated in the Commission’s Interference Protection Public Workshop, had certain television receiver standards been implemented, this frequency assignment constraint would not have been necessary and there would have been adequate television channels to satisfy demand.[19]
As the Commission states in the NOI, one effect of minimally performing receivers has been demonstrated as licensees seek protection for service predicated on the performance of receivers with little tolerance for other signals. Had the expected performance characteristics of these receivers been defined, these services could have been developed with receivers that could better tolerate the introduction of new services on the same or proximate frequencies.[20]
NTIA believes that knowledge of the expected immunity performance to non-cochannel signals is required to be able to assess the likelihood of interference from new transmitters and to more effectively and efficiently manage spectrum resources.
VI. NTIA RECOMMENDS THAT THE COMMISSION GIVE FIRST PRIORITY TO ADOPTING STANDARDS FOR NEW ALLOCATIONS.
As the Commission states in the NOI, with the large number of communications services that are currently in operation, a program to study and define minimum receiver performance specifications across all radio services will be a substantial undertaking. The Commission requests comment and suggestions on how to plan for and manage such a program should it be undertaken. In particular, comments and suggestions are requested regarding the services and/or receiver types with which to begin.[21]
NTIA recommends that the Commission give priority to considering those services that are newly developing and where there are few legacy receivers. Because of the lack of legacy systems in these bands, a decision by the Commission to implement receiver standards would have the greatest opportunity to be effective. Among others, these bands include many of the recently reallocated bands previously used by the Federal Government. Although not necessarily newly allocated, NTIA also recommends that the Commission give priority to those bands adjacent to government bands where the latter have high power transmitters.
Of particular concern to NTIA are the bands that have recently been reallocated from the Federal Government to the private sector. Because of the large spectrum requirements of the Federal Government and the mandate to avoid excessive costs or serious degradation to federal operations, most of these bands were identified with some degree of encumbrance. These encumbrances generally include continued federal operations within certain bands at specific sites and continued federal operations in adjacent bands. Introduction of new services and systems in these bands could open up a significant number of potential adjacent band interference problems. In the Spectrum Reallocation Final Report, NTIA stated “in order to achieve the goals set by Title VI for development of new technologies, adoption of effective receiver standards, either regulatory or established by industry, is essential for bands identified in the final plan that are adjacent to high-power federal systems.”[22]
VII. NTIA SUPPORTS THE COMMISSION’S FLEXIBLE APPROACH TO ADOPTING RECEIVER STANDARDS.
In developing receiver immunity performance standards, NTIA agrees with the Commission that many different approaches, including voluntary and mandatory, service specific and generic, as well as other options should be considered.[23]
Voluntary standards could be self-enforced by the Commission only protecting services for which receivers meet the recommended standard. Labeling could also be used to induce consumers to procure equipment meeting standards. In addition, as the Commission stated in its Changes to the Rules Relating to Noncommercial Educational FM Broadcast Stations, the Commission could let it be known that if voluntary standards are not sufficient, then mandatory standards could be imposed.[24] Other areas of flexibility are suggested in the NTIA Report.[25] NTIA urges the Commission to work with industry to develop an approach that will be effective, but impose a minimum of hardship and disruption.
VIII. CONCLUSION
NTIA supports the Commission’s efforts in considering the inclusion of interference immunity performance standards for radio receivers in its regulations. NTIA urges the Commission to consider carefully the issues raised in these comments and in the NTIA Report.
NTIA looks forward to working with the Commission and industry in developing the appropriate regulatory framework to accomplish this important task.
Respectively submitted,
Michael D. Gallagher Kathy Smith
Acting Assistant Secretary for Chief Counsel
Communications and Information
Fredrick R. Wentland National Telecommunications and
Associate Administrator Information Administration
Office of Spectrum Management U.S. Department of Commerce
1401 Constitution Avenue, N.W.
Bernard Joiner Room 4713
Electronics Engineer Washington, DC 20230
Office of Spectrum Management (202) 482-1816
November 12, 2003
NTIA Report 03-404
RECEIVER SPECTRUM STANDARDS
Phase 1 - Summary of Research into Existing Standards
ENDNOTES:
[1] In the Matter of Interference Immunity Performance Specifications for Radio Receivers, ET Docket No. 03-65, Notice of Inquiry, 68 Fed. Reg. 23677 (May 5, 2003) (“NOI”).
[2] Spectrum Policy Task Force Report, Federal Communications Commission, ET Docket No. 02-135 at 31, 33 (November 15, 2002) (“FCC Task Force Report”).
[3] Manual of Regulations & Procedures for Federal Radio Frequency Management, National Telecommunications and Information Administration (2003).
[4] National Telecommunications and Information Administration, Receiver Spectrum Standards, Phase 1, Summary Of Research Into Existing Standards, NTIA Report No 03-404 at 7 (November 2003) (“NTIA Report No. 03-404”).
[5] NOI at ¶ 6.
[6] FCC Task Force Report at 11-15; NOI at ¶ 6.
[7] NTIA Report No. 03-404 at 35.
[8] Examples of many of these standards are given in NTIA Report No. 03-404.
[9] NTIA Report No. 03-404 at 15-34.
[10] NOI at ¶ 19.
[11] National Telecommunications and Information Administration, Analysis of Electromagnetic Compatibility Between Radar Stations and 4 GHz Fixed-Satellite Earth Stations, NTIA Report No. 94-313 (July 1994).
[12] National Telecommunications and Information Administration, Ground-Based Weather Radar Compatibility with Digital Radio-Relay Microwave Systems, NTIA Report No. 90-260 (March 1990).
[13] National Telecommunications and Information Administration, Measured Characteristics of Selected Non-Licensed Devices, NTIA Technical Memorandum 91-149 (April 1991); Haley, J, Navy can’t close door jams, Everett Herald, Everett (June 5, 1998).
[14] Transcript (Trans.) of Federal Communications Commission Interference Protection Public Workshop, at 133 (August 2, 2002) (available at http://www.fcc.gov/sptf/files/0802fcc.pdf ).
[15] National Telecommunications and Information Administration, Evaluation of Marine VHF Radios: Performance in the Savannah, Ga. and New Orleans, La. Port Areas, NTIA Report No. 99-362 (April 1999).
[16] Comments of Federal Aviation Administration (July 20, 2003).
[17] NOI at ¶ 1.
[18] NOI at ¶ 10.
[19] NTIA Report No. 03-404 at 2; Trans. at 133.
[20] NOI at ¶ 2.
[21] NOI at ¶ 24.
[22] National Telecommunications and Information Administration, Spectrum Reallocation Final Report, Response to Title VI – Omnibus Budget Reconciliation Act of 1993, NTIA Special Publication 95-32 at v (February 1995).
[23] NOI at ¶ 18.
[24] Changes to the Rules Relating to Noncommercial Educational FM Broadcast Stations, Memorandum Opinion and Order, Docket No. 20735, FCC 85-328 (released June, 1985).
[25] NTIA Report No. 03-404 at 36.