Analysis of Potential Interference Issues Related to FCC Order 20-48 (2023) / Chapter Skim
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3 Additional Matters
3 Additional Matters
Pages 78-85
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From page 78... ...
The following observations are offered with the hope that future proceedings might provide more streamlined and optimized approaches to balancing the desire to protect and enable incumbents while maximizing the economic and operational benefits provided by new entrants into a given spectrum region. 3.1 TOWARD A BET TER MEANS OF ASSESSING HARMFUL INTERFERENCE It is important to understand why a large number of different communities reached diametrically opposed opinions on the likelihood of "harmful interference" from the Ligado license on Global Positioning System (GPS)
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From page 79... ...
, and receivers have not historically been part of the regulatory process. However, the committee believes that the FCC, working together with industry and government participants, can come up with measured levels for harmful interference in a given band of spectrum based on the intended usage in that band and based on near past and state-of-the-art receiver performance in the presence of significant adjacent-band power.
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From page 80... ...
If the FCC were to adopt future guarantees about adjacent-band power masks, the masks could be changed over time as receiver design technology improved. If the promise were, for example, for a 15-year period, then every 5 years a revised future mask guarantee could be published for the coming 15-year future interval over which no mask guarantee had yet been made.
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From page 81... ...
Therefore, some other factors that should be considered include the following: • The lifetime of many devices is shorter than the time in which major changes in spectrum are identified, considered and accepted, and then implemented. For example, smart watches, cell phones, and similar consumer equipment may go through many generations during the time it takes to consider even one spectrum usage change.
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From page 82... ...
Spectrum processes must reflect that the environments will change, impacting both users of the immediate spectrum, and adjacent bands. Issues such as the varying equities inherent in the authorization of the Ligado system or in the controversies surrounding the implication of the 5G rollout on radio altimeters are not outliers and are not unique; they will become commonplace as new uses emerge and compete with older ones.
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From page 83... ...
3.2.3 Administrative Process In the course of its information gathering, the committee inquired of the FCC witnesses why, given the objections they raised regarding some positions provided in FCC filings, the FCC apparently did not consider introducing less rigorous protections than were asked for (yet more rigorous than are currently in the ruling)
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From page 84... ...
3.2.5 Toward a More Collaborative Model of the Spectrum Process The previous section discussed the inherent limitations of resolving spectrum issues through a process more akin to litigation than to engineering judgment. A similar is sue arises from the separation of spectrum management responsibilities in the United States between federal and non-federal spectrum.
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From page 85... ...
It is important to note that many commercial spectrum rights issues have been resolved directly between the parties through some negotiated framework, which presumably balances the costs and risks to the participating parties. The FCC has greatly encouraged this process in the past, as regulators do not have to choose "winners and losers"; presumably, market forces resolve the issue.
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