ARLA/CLUSTER: ARRL encourages comprehensive Noise Floor study

[João Costa > CT1FBF]

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.

Fonte: The American Radio Relay League