NTIA Tells FCC It Already Considers Receiver Characteristics

“As part of NTIA’s system certification process, we routinely collect information regarding relevant characteristics of receiver performance, depending on the service and system type,” the agency said in docket 22-137. Agencies requesting certification of land mobile radio systems in the 162-174 and 406.1-420 MHz bands “are required to provide information regarding their spurious rejection, adjacent channel rejection, and intermodulation rejection, and those requesting certification of radar systems are required to provide information regarding radio frequency and intermediate frequency filter selectivity, spurious rejection, and stability,” NTIA said.

“In many cases” receivers are required to meet performance standards, NTIA said: “In some cases, involving land mobile and fixed systems, these standards are identical to those developed by the Telecommunications Industry Association. In other cases, involving radar systems, the standards were developed by NTIA with assistance from the relevant agencies.”

CTA supported the general inquiry but opposed regulation. “Standards for receiver performance derive from transmission technical rules and should be left to industry so that new innovative technologies can be implemented quickly,” the group said: “The Commission should not adopt government-mandated receiver performance standards or interference thresholds.” CTA warned that high-level policy statements based on general principles for spectrum management may have some value, but even such statements will need to be applied on a case-by-case basis.”

“Refrain from unnecessary regulation where competitive markets and industry cooperation have been successful in improving the interference immunity of certain classes of communications equipment,” said CTIA. “Rather than attempting to consider all spectrum bands and allocations as a whole,” the FCC “could carefully tailor its investigation of receiver performance improvements by selecting a new or less efficiently used allocation (or allocations) as a pilot to test the use of any new requirements or guidance for receivers,” the group said. CTIA said the agency should work with NTIA to look at federal operations in the pilot band.

T-Mobile is open to additional FCC involvement on receivers. “A light-touch” regime “does not mean no-touch,” T-Mobile said: “Indeed, the Commission already effectively regulates receivers by structuring transmitter regulations to protect receivers. It can also consider more direct regulation that will dictate when and to what extent receivers are entitled to protection.” Verizon said the FCC should consider offering “general policy guidance that emphasizes the important role that receiver interference immunity plays in sound spectrum management.” Verizon encouraged the FCC to focus on bands “where operators or vendors lack incentives to develop and deploy high-performing receivers.”

Several standards groups and other industry organizations already address receivers and the FCC should rely on their work, CommScope said. “We urge the Commission to look to industry frameworks to address receiver performance instead of undertaking a potentially time-consuming, complex and costly approach to regulation of receiver performance,” the company said.

Ericsson counseled the FCC to rely on industry standards, technical inquiries, policy statements and interference limits to address receivers. “Different approaches will be necessary based on the particular circumstance of a given band or service,” Ericsson said: “For operators with incentives for robust receiver performance, like commercial wireless services, policymakers should continue to acknowledge market forces to drive investment in and deployment of high-performing receiver technology.”

Don’t impose standards and be wary of harm-claim thresholds, Cisco advised. “Transmitters and receivers that operate in licensed as well as unlicensed bands have become far more sophisticated as manufacturing has evolved to meet 21st century needs,” Cisco said: “While some manufacturers may have once favored 'wide-open' receivers to increase sensitivity to locate low-power signals, the increased number and power of devices operating in the same or adjacent frequency bands has pushed the industry to design resilient equipment that rejects unwanted signals.”

The American Radio Relay League said receiver standards wouldn’t be appropriate for amateurs. “Unlike the commercial services, in the Amateur Service many of the amateur bands are used in a relatively free-form manner without channelization and with signals of different bandwidths, modulation types, and signal strengths adjacent to each other simultaneously in an ever-changing ad hoc arrangement,” ARRL said: “Coexisting with different and unexpected signals, as well as widely varying and continually changing signal propagation in bands such as those at high frequencies (HF) are a continual part of operations and experimentation.” The GPS Innovation Alliance said the FCC should take into account differences in services and “not inadvertently jeopardize services like GPS, “the characteristics of which are different from communications-centric services that the Commission has historically regulated.”

Public Knowledge and the Open Technology Institute at New America urged the FCC to craft a standard receiver framework. “The Commission should state in any NPRM proposing a new spectrum access regime that it assumes certain basic characteristics of any receiver potentially impacted by the Commission’s decision. Licensees (or other relevant stakeholders) may then make the decision as to whether they wish to continue to offer ‘substandard’ receivers or only receivers that meet or exceed the standards defined by the Commission,” the groups said. Offer “no protection for devices that listen out of band,” they advised. The groups also said the FCC has authority to act: “The Commission’s definition of the spectrum environment is what it is, and licensees must simply accept it as they accept the impacts of geography or solar flares and design their systems accordingly.”