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Stakeholders Weigh in on Radio Spectrum Noise

One thing on which almost all agree: It’s time for the noise floor to be analyzed more closely

Let’s get going.

That’s the gist of many comments about spectrum noise that have been submitted to the Federal Communications Commission Technological Advisory Council in its current inquiry. Based on Radio World’s sampling of the filings, most agree that new research is needed.

“A new noise floor study seems to be a critical requirement to establish future spectrum policy that enables the full potential of the Internet of Things and machine-to-machine communications,” wrote Philips Lighting North America. The manufacturer was one of several to mention that noise seems to have improved with the transition of U.S. television from analog to digital; a noise floor study “will enable the potential future allocation of any additional portions of the spectrum,” Philips said.

The EMRadiation Policy Institute, a nonprofit that looks at effects of electromagnetic radiation, told the FCC advisors that any study should take into account the geology, biology, technology and engineering elements necessary to describe the radio spectrum noise floor; and to even determine whether there is an increasing problem, it should include experts who possess sufficiently broad knowledge to ask pertinent questions and collect meaningful data. “At issue is the question of interference with all manner of electronic devices as well as with the users of those devices and the natural and man-made ecosystems in which devices, users and all life coexist.”

Others, like AARL, the national association for amateur radio, say it’s high time that the noise floor issue be organized and analyzed. Only then will the commission “have a firm basis for deciding whether current noise standards are too tight, too loose, or appropriate,” it wrote.

“Many of these individual sources of RF noise may be consistent with current commission rules, but in some cases, individually and in the aggregate, they may (and ARRL believes that they do) negatively impact the overall electromagnetic noise environment,” it wrote. “Because the commission’s resources are woefully inadequate to address RF noise through widespread enforcement of Part 15 and Part 18 rules governing RF emitters after the devices are deployed, the only reasonable means of dealing with them is to enact and enforce, ex ante, appropriate rules for RF emitters that are based on actual knowledge of the noise floor and trends over time.”

The Society of Broadcast Engineers, which has been vocal on the issue of spectrum noise, wrote: “It is clear that, starting well more than a decade ago, the need for a thorough investigation of the RF noise floor in various environments has been repeatedly acknowledged to be a prerequisite to and a necessary first component of any improved spectrum management plan in a given frequency band.

“Surprisingly, however,” the SBE continued, “and despite the clear acknowledgement that these studies were necessary, no progress in performing such seems to have been made between May of 1999 and the present time.”

The case for a comprehensive evaluation of the ambient noise environment, especially in the medium-frequency, high-frequency, VHF, UHF and low microwave ranges becomes more compelling all the time, the engineering group said.

It also pointed a finger at the commisison, saying the FCC’s unwillingness to issue meaningful sanctions against operators of incidental and unintentional radiators — like power lines — has led to the virtual absence of any incentive by power utilities to comply with its Part 15 non-interference obligations.

The SBE also pressed the commission to focus specifically on a plan to reduce RF noise in the medium-wave band, where AM stations operate.

The National Public Safety Telecommunications Council recommended that the commission consider the need for additional study on potential RF noise from wind farm systems and solar system power inverters as well as consider the the potential increase in noise from out-of -and emissions as cell sites proliferate.

Others like wireless group CTIA support the initiatives already started by the TAC. But CTIA urges caution, saying investigation of the noise floor should not lead to erosion of licensees’ rights to fully utilize their spectrum, nor be leveraged to support the introduction of unlicensed or underlay experiments in the Commercial Mobile Radio Service spectrum.

DTS Inc., parent of HD Radio, has no doubt there is a significant noise problem affecting radio services. The company cited a series of studies of the interference environment in the AM and FM bands, and points to the cumulative impact of noise from components in radio receivers, from overhead power lines and in-house wiring, and from the proliferation of devices with a switching power supply. The introduction of new electronics in the home and car may cause further deterioration, DTS wrote.

“In particular, the introduction of advanced electronics associated with smart and autonomous vehicles could greatly increase noise,” because those vehicles use a large number of sensors, radar and other transmissions to sense other cars, people and objects, and to allow for communication between autonomous vehicles. “All these enhancements have the potential to introduce new noise that will impair radio service,” DTS wrote.

Individuals also weighed in on the issue, including Frank McCoy, a translator licensee in Waukegan, Ill., who pressed the commission to act on its authority to limit electromagnetic pollution “in exactly the same way as the EPA regulates other forms of environmental damage.”

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