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If You Think There’s a Noise Floor Problem, Speak Up Now

Here's what one engineer is telling the commission it should do

“Why isn’t the FCC doing their job?”

That question has been asked before in the broadcast community regarding problems of noise from a growing number of unlicensed electronic sources. It is being asked again in comments filed to the Federal Communications Commission’s Technological Advisory Council.

As we’ve reported, the council is asking the public right now about whether there’s a noise floor problem and how bad it is. The deadline is tomorrow (Aug. 11). Only about three dozen comments have been filed so far, by Radio World’s count in the FCC’s online database, though some organizations tend to wait until the filing deadline.

The question above was put by Frederick Vobbe, an engineer who tells the commission in written comments that he has worked in broadcasting and cable since 1968. He is an active ham, he has helped the FCC in locating radio pirates and he is a regional EAS co-chairman and past public information officer for a county office of emergency management.

“For years the level of interference from terrestrial noise sources has steadily increased,” he wrote. “The interference issue is not unique to the United States. Other countries struggle with noise. What is different is other countries have recognized the problem and threat to citizens. They have begun working toward resolutions, which includes the prosecution of violators.”

Complicating the problem, he said, “With analog devices the consumer was able to identify interference. With digital devices the majority of consumers do not know why a device stops working or performs poorly. The public has been cheated out of receiving the quality and performance they expect from their purchase. The public is also threatened by buying safety and security equipment which may not work due to interference from other equipment. Interference and noise is a direct danger to citizens impacting their ability to access NOAA WX Radio, EAS, amateur radio, and is a threat to law enforcement and first responder communications.”

Vobbe concluded that interference and noise have forced broadcasters to incur losses in audience, revenue and public service. “One has to reasonably question if AM/FM/TV broadcasters are damaged with malice, and should be compensated for losses of service area or viewer/listeners.”

The commission, he said, should demand that all users and manufacturers eliminate intentional or unintentional interference within three months.

“Additionally, the FCC should require all manufacturers of equipment out of compliance to inform their customers by mail or advertisement that they own a device which is non-compliant,” he continued.

“Public utilities, municipalities and common carriers should publish a contact phone number in each community where they provide service for reporting interference. Once reported, a resolution should be made within three business days. All correspondence in these matters shall be public record. Fines should be implemented when owners of offending devices do not exhibit a reasonable resolution the problem. Financial compensation should be made to victims for interference, or providing materials and labor at no charge for the resolution to the problem.”

You can read Vobbe’s filing here (PDF).

Comments to the FCC are being accepted through tomorrow, using the commission’s Electronic Comment Filing System. File comments under docket number 16-191.

AFCCE Urges Members to Sound Off About Spectrum Noise