Subject: [NEXTEL-1] FCC Commisioner Comment On- Interference Immunity Performance Specifications for Radio Receivers; ET Docket No. 03-65.

From: Marcel <[email-masked]>
Date: Mon, 24 Mar 2003 16:40:13 -0500

FCC Commisioner Comment On- Interference Immunity Performance Specifications for Radio
Receivers; ET Docket No. 03-65.s

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SEPARATE STATEMENT OF
CHAIRMAN MICHAEL K. POWELL

Re: Interference Immunity Performance Specifications for Radio Receivers; ET Docket No.
03-65.

The Spectrum Task Force has offered a number of proposals for refining the FCC’s approach
to interference and developing better metrics for describing and quantifying the
interference environment in particular bands.  The development of receiver standards is an
integral part of this effort.  Spectrum is too critical a resource in our digital economy
to allow interference avoidance to be addressed on an ad hoc incremental basis.  All
factors that contribute to the interference environment and, ultimately, the ability of
users to receive clear radio signals, must be taken into account as early in the process
as possible.

Technological advancements in the ability to reject unwanted signals and the filtering
capacity of radio receivers present the Commission with an opportunity.  In a world where
spectrum sharing is increasingly necessary and common, more selective receivers reduce the
need for the Commission to become mired in paralyzing interference debates pitting
incumbents against new entrants.  Instead, shared expectations about the characteristics
of receiver equipment allow all parties to plan for and mitigate interference.

As we initiate this proceeding, our objective is to gather information on the
technological landscape – what is the state-of-the-art in receiver technology and what is
deployed in the field.  Without baselines, there can be no benchmarks.  In developing
these baselines, I prefer to rely on market incentives and voluntary industry programs to
establish receiver immunity guidelines in the first instance.  Such guidelines will
promote more efficient use of the radio spectrum, increasing opportunities for innovation
and the delivery of new services to the American public.
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SEPARATE STATEMENT OF
COMMISSIONER KATHLEEN Q. ABERNATHY

Re:  Interference Immunity Performance Specifications For Radio
Receivers (ET Docket No. 03-65); Review of the Commission’s Rules and
Policies Affecting the Conversion to Digital Television (MM Docket No. 00-39),
Notice of Inquiry

Today’s NOI is an important step toward improving the Commission’s spectrum management
policy.  As part of its approach, the FCC traditionally has relied primarily on approaches
that control the emissions and locations of transmitters and the frequencies used by
specific types of radio operations.  While this method has worked in the past, the
changing pace of technology and the increasing demands placed on the spectrum resource
indicate that it is time for the FCC to look into changing its approach.  Accordingly, and
as recognized in the Spectrum Task Force Report, I believe that this NOI moves the FCC  in
the right direction by promoting a more flexible and market-oriented approach to setting
interference immunity performance standards for radio receivers.

Today’s NOI sets the stage for the FCC to gather data from all interested parties on ways
to ensure flexibility to allow for the introduction of new digital radio technologies and
to allow licensees the flexibility to implement new technologies in receiver standards.
Importantly, the NOI proposes to accomplish this through the imposition of both voluntary
guidelines and, where appropriate, mandatory rules. This approach is consistent with my
view on spectrum management that where possible, the FCC should afford licensees
flexibility in the deployment of technologies.

At the end of the day, this proceeding will have a direct impact on the every day life of
American consumers.  For example, the information gathered in this proceeding will form
the basis for the interference standards for many of the items we each use on a daily
basis including the next generation of digital televisions and AM/FM radios.  I look
forward to gathering a record in this proceeding that will help us harness the enormous
potential of spectrum-based services to bring to consumers innovative technologies and new
services.

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SEPARATE STATEMENT OF
COMMISSIONER MICHAEL J. COPPS

RE:   Interference Immunity Performance Specifications for Radio Receivers; Review of the
Commission’s Rules and Policies Affecting the Conversion to Digital Television, ET Docket
No. 03-65, MM Docket No. 00-39

 This NOI is important and forward looking.  I commend the Chairman and OET for beginning
the process of systematically exploring how the Commission can further our statutory
responsibility to increase the efficiency and intensity of use of the spectrum through
receiver standards.  The Commission usually focuses on transmitters in interference
disputes.  This, potentially, is a mistake.  We must understand whether there are actions
that industry and the Commission can take to ensure that unreasonably fragile receivers do
not undermine the efficient use of our spectrum resource.  But we must also understand the
costs of designing more robust receivers.  This NOI will begin that process, and I look
forward to receiving a full record.
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SEPARATE STATEMENT OF
COMMISSIONER JONATHAN S. ADELSTEIN

Re: Interference Immunity Performance Specifications for Radio Receivers; ET Docket No.
03-65; Review of the Commission’s Rules and Policies Affecting the Conversion to Digital
Television; MM Docket No. 00-39

 I believe that our proceeding on receiver performance standards will turn out to be one
of the most significant spectrum management proceedings that the Commission initiates in
the near future.  The members of the Spectrum Policy Task Force should be commended for
highlighting this issue in their recent report.

 I have said in the past that, when it comes to spectrum management, we need to do “more
with less.”  Spectrum is a finite resource, and our goal as policymakers is to make the
spectrum stretch farther and farther so that it can accommodate more and more users as
well as the newest service offerings.  Innovation swirls all around us, and as regulators
we need to make sure that we always consider the latest technologies in developing policy,
especially in considering spectrum policy.  When an engineering opportunity comes to
light, such as receiver performance standards, it is our obligation to fully investigate
its possibilities.

 I fully support this inquiry into receiver performance standards because it takes an
important first step towards improving our country’s access to spectrum.  This in turn
should provide for improved radio communications services to the public.  When it comes to
spectrum, doing more with less is essential because the wireless industry thrives on
innovation and engineering.  These characteristics regularly lead to advances in capacity
and service offerings - demonstrating that you sometimes truly can do more with less.
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SEPARATE STATEMENT OF
COMMISSIONER KEVIN J . MARTIN

Re: Interference Immunity Performance Specifications for Radio Receivers, Review of the
Commission’s Rules and Policies Affecting the Conversion to Digital Television, Notice of
Inquiry, ET Docket No. 03-65, MM Docket No. 00-39

 I am pleased to support this Notice of Inquiry (NOI), which explores standards for
receivers’ immunity from interference.  The Commission has traditionally approached issues
of interference by focusing solely on transmitters, regulating their emissions and
locations.  However, the experience of interference is a function of the interaction
between both transmitters and receivers.  The Commission’s Spectrum Task Force thus
recommended that the Commission consider applying performance requirements to receivers.
This NOI builds on the recommendations of the Task Force and seeks input on whether and
how the Commission could promote receiver standards, either through incentives, voluntary
industry actions, regulatory mandates, or some combination of these approaches.  The use
of receiver standards – when coupled with guidelines for transmitters – could dramatically
reduce the potential for harmful interference.  This would allow for greater sharing of
spectrum, which is critical to address the growing demands on what is currently a finite
resource.  Indeed, had receiver standards been in place in the past, we might not face
many of the interference problems we do today.  I thus welcome the commencement of this
inquiry and look forward to reviewing the comments in this proceeding.

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