[SFDXA] ARLB030 ARRL Encourages Comprehensive Noise Floor Study

[William Marx]

> SB QST @ ARL $ARLB030
> ARLB030 ARRL Encourages Comprehensive Noise Floor Study
> 
> ZCZC AG30
> QST de W1AW  
> ARRL Bulletin 30  ARLB030
> From ARRL Headquarters  
> Newington CT  August 16, 2016
> To all radio amateurs 
> 
> SB QST ARL ARLB030
> ARLB030 ARRL Encourages Comprehensive Noise Floor Study
> 
> In anticipation of an FCC Technological Advisory Council (TAC)
> investigation into changes and trends to the radio spectrum noise
> floor to determine if there is an increasing noise problem, ARRL
> asserted that such a study is long overdue. The FCC Office of
> Engineering and Technology (OET) announced plans for the TAC study
> in mid-June and invited comments and answers to questions that the
> TAC posed concerning the methodologies for such a study. The
> League's comments also praised the TAC - an advisory group to the
> FCC - for tackling the issue and expressed the hope that the noise
> study might, for the first time, provide a useful, objective basis
> for spectrum overlays and other future allocation decisions. ARRL
> allowed that while a noise floor problem exists, "The magnitude of
> this problem and the extent of it in the 21st century is virtually
> unknown."
> 
> "The TAC and the leadership in this study initiative are to be
> congratulated for finally undertaking what has been universally
> determined to be necessary for well more than 2 decades," the ARRL
> said. "The Commission should not have made spectrum management
> decisions without this noise information, and it is unfortunate that
> the initiative has been delayed this long."
> 
> The ARRL said that its members can be of use in gathering data for
> the TAC noise study, but advised that any urgency in initiating the
> study "be tempered by the prerequisite need to develop a
> standardized and valid methodology for conducting the study," in
> order to "obtain quantitative data regarding the noise floor in
> various environments and trends over time," ARRL said.
> 
> ARRL said the focus of the TAC noise "study should be an accurate
> determination of what noise levels exist in as wide a range of
> indoor and outdoor environments as possible. It should, to the
> extent possible, determine what types of noise are being found:
> Broadband, non-specific noise; broad noise spectral peaks; broadband
> digital noise; and noise occurring on discrete frequencies."
> 
> "We also hope that these comments will serve as a stimulus for the
> Commission to re-evaluate its 'hands-off' policy with respect to the
> most recalcitrant and unhelpful operators of incidental and
> unintentional radiators which are causing long-term interference
> problems, such as electric utilities," ARRL concluded. "The
> unwillingness of the Commission to issue meaningful sanctions has
> led to the virtual absence of any incentive to comply with the
> Commission's Part 15 non-interference obligations."
> 
> ARRL pointed out that the FCC had requested that the TAC study the
> noise floor in 1999 and propose new approaches to spectrum
> management based on emerging and future technologies. "The TAC
> concluded that it would be impossible for the Commission to engage
> in effective spectrum management until it 'develop[s] a more
> complete understanding of the current state of the radio noise
> environment,"' ARRL recounted, noting that TAC urged the Commission
> to immediately undertake a multi-part noise floor study and
> cautioned it against implementing new spectrum management techniques
> or initiatives without first concluding extensive studies.
> 
> "Yet, 16 years later, no such study has been conducted," ARRL said.
> "Now, and for the past several decades, new noise sources are being
> developed and have been developed and the proliferation of
> electronic devices continues as fast as the technology and the
> regulatory processes will allow." While many individual sources of
> RF noise may be consistent with FCC rules, in some cases they may
> negatively impact the overall electromagnetic noise environment,
> ARRL said.
> 
> "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," ARRL said. "The
> growing number of interference complaints indicates that any
> increase in noise levels will result in harmful interference, so
> these rules may need to require a decrease in the permitted limits
> for emission to balance the aggregate noise potential of a growing
> number of noise emitting devices."
> 
> The League's comments include a bibliography, "Articles Relating to
> the Description, Impact and Study of Man-Made Noise," compiled by
> ARRL Lab Manager Ed Hare, W1RFI.
> NNNN
> /EX