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The Radio Frequency Environment: FCC’s Role in Preserving and Maximizing a National Resource

The Radio Frequency Environment: FCC’s Role in Preserving and Maximizing a National Resource. April 11, 2017 Thomas King Jonathan Edwards Donald Everist Robert Weller. AFCCE – The Radio Frequency Environment. About AFCCE.

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The Radio Frequency Environment: FCC’s Role in Preserving and Maximizing a National Resource

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  1. The Radio Frequency Environment: FCC’s Role in Preserving and Maximizing a National Resource April 11, 2017 Thomas King Jonathan Edwards DonaldEverist Robert Weller

  2. AFCCE – The Radio Frequency Environment About AFCCE • Founded in 1948 as a professional association of engineers practicing before the FCC • Over 200 members, focused on technical policy matters relating to telecom • Monthly meetings in DC area with technical presentations • Awards $60,000 in scholarships annually to students interested in telecom engineering • Some recent FCC comments: • OET/TAC Noise Inquiry • AM Synchronous Boosters and AM Revitalization • ATSC 3.0

  3. Preserving and Improving the RF Environment • RF Noise Inquiry (ET Docket 16-191) • Critical Need for Enhanced Enforcement • AM Synchronous Boosters (RM 11779) • The Case for Nationwide AM Transmitter Synchronization

  4. RF Noise:Absolute Need for an Updated Spectral Noise Study “There hasn’t been a systematic study of radio-frequency noise in the US since the mid-1970’s, when the Institute for Telecommunications Sciences (ITS), a part of the National Telecommunications and Information Administration, last monitored federal use of the radio spectrum.”* * “Phone to Fridge: Shut Up!” (“Electronic Noise is Drowning Out the Internet of Things”) by Mark A. McHenry, Dennis Roberson & Robert J. Matheson, IEEE Spectrum, Vol. 52, No. 9, Sep. 2015

  5. FCC TAC RF Noise Floor Technical Inquiry (ET Docket 16-191) • NOI released on June 15, 2016 • Questions posed included: • Is there a noise problem • Where does the problem exist? Spectrally? Spatially? Temporally? • Is there quantitative evidence of the overall increase in the total integrated noise floor across various segments of the RF spectrum? • How should a noise study be performed? 5

  6. Summary of Responses to RF Noise Inquiry 93 responses Clear consensus that an updated noise floor study is not only needed, but is long overdue AM/FM radio, TV, wireless, public safety and other services are significantly compromised due to the rising noise floor Significant ramifications for low-power IoT sensor networks Operational service degradation experiences as were provided by numerous respondents demonstrate the need for noise floor remediation as it affects almost all communications

  7. Major Contributors to the Rising Noise Floor • Broad agreement as to the major contributors to the rising noise floor: • Fluorescent and LED lighting • Computers and imbedded controllers • Switching power supplies and battery chargers • Cable TV/internet distribution systems • Power line communications (PLC) & Broadband over power lines (BPL) • Electric automobiles (Noise from electric motors and motor controllers) • Overhead Power Lines (Contaminated or failed insulators)

  8. International Concerns Echo NOI Comments ITU-R Assessment of the impact of unwanted radio frequency energy generated by non-radiocommunication equipment to radiocommunication services * “Many types of electrical and electronic equipment are seen to be involved, particularly those using switch mode power supplies and power conversion stages… particular problems associated with LED lighting and increasing noise levels … In addition there are continuing concerns and emerging reports of interference from high performance broadband/CATV distribution systems…” • * Working Party 1A Liaison Statement to Working Parties 1C, 3L, 5A, 5C, 6A, 7A and 7D (Dec. 15, 2016):

  9. AFCCE Recommendations to Address Increasing RF Noise New/updated web-based FCC “Interference Handbook” that includes a compendium of noise manifestations associated with various consumer products and an explanation of how to contact the FCC or the manufacturer of the products to alert them to these problematic noise sources Re-establish a post-marketing “sampling and measurements” program to randomly test consumer electronic products and lighting products for compliance with Part 15 and Part 18 rules Establish a measurement program for monitoring noise levels in the US on an ongoing basis in urban, sub-urban and rural areas over the DC to 70 GHz spectrum Consider revising spectral emission limits on intentional, unintentional, and incidental emitters to reflect modern technologies

  10. Enhanced Enforcement: Recommendations Implement an online portal to allow licensees to file official interference complaints with a clear understanding of the steps to be taken to resolve them FCC should take a lead role in monitoring and documenting interference problems and institute industry work groups to resolve common problems As a result of the reduction in FCC field enforcement, licensees are forced to use their own resources to locate unauthorized stations and must attempt to utilize local law enforcement personnel to force them to shut down Re-establish a program of random inspections in all services Due to lack of routine monitoring and inspection, licensees are being impacted by the unlawful practices of other licensees operating at variance from their authorizations. Licensees must use their own resources to locate and directly approach the offenders. Some cooperate and some do not. The FCC cannot continue to turn a blind eye toward the real world of pirate and “at variance” practices that are becoming more the norm than the exception

  11. AM Synchronous Boosters (RM-1177) Nov. 7, 2016 Letters from FCC Audio Division to the licensee of three AM Synchronous Booster stations in Puerto Rico orders discontinuance of operation within six months Nov. 17, 2016 licensee response seeks urgent reconsideration of the order Nov. 29, 2016 CGB seeks comment on Petition for Rulemaking to permanently authorize AM Synchronous Boosters Supportive comments received, including a recommendation to allow the Puerto Rico stations to continue to operate pending the outcome of the PRM No apparent action on PRM or reconsideration request NPRM should be issued and Puerto Rico stations allowed to continue licensed operations on a non-interference basis

  12. Synchronous AM Boosters for Null Fill Typical cardioid pattern Synchronous booster fill-in area Low-power, low-cost synchronous boosters can provide useful fill-ins for covering populated areas lying in pattern nulls. Boosters can be used daytime and/or nighttime as needed. Coverage of outlying suburbs can be greatly improved. Allocations can generally be handled under existing rules.

  13. Coverage Map of Puerto Rico AM Synchronous Boosters Approximate locations of 2 mV/m contours shown Booster 3 Booster 2 WISO 13

  14. Summary of AFCCE Comments to RM-1177 Allow “fill-in” boosters without restriction within primary station’s 2 mV/m contour Allow AM synchronous boosters to expand coverage beyond the primary station’s contour, so long as there is some overlap of the 2 mV/m contours Each synchronous booster station must fully protect other stations Synchronous boosters may operate either Non-D or DA Synchronous boosters may operate with lesser or greater power than the main station subject to the above constraints All stations in network maintain carrier frequency within +/- 0.2 Hz All stations in network must rebroadcast the primary station’s content, including maintaining proper audio phasing Boosters are secondary operations under Part 74

  15. Permanent Licensing of AM Synchronous Boosters Media Bureau should proceed with a rulemaking to authorize permanent licensing of AM synchronous stations in the US under Part 74 (secondary service) to open the door for AM broadcasters to have this option available to them to better serve their target audiences There is no technical reason why the current AM synchronous booster stations should not be allowed to continue operation during the pendency of this rule-making in accordance with the guidelines that AFCCE has endorsed Benefits: Fill-in coverage in “pattern nulls” using low-power and at low-cost Daytime and/or nighttime as needed Coverage of outlying suburbs can be greatly improved Allocations can generally be handled under existing rules

  16. Nationwide AM Transmitter Synchronization: Pros and Cons Synchronization reduces interference. Enlargement of coverage area: 4 to 10 fold increase in equivalent listening area). Eliminates annoying “beats,” which are the most objectionable interference effect at AM and the source of most tune-outs. Minor or no equipment modifications; low cost. Huge bang for the investment buck for broadcasters! Concern: all stations need to synchronize or little benefit!

  17. Example of AM Synchronous Coverage Improvements New daytime coverage area New nighttime coverage area 0.5 mV/m 2.0 mV/m 1.0 mV/m

  18. Real AM Revitalization Develop an achievable set of goals through the TAC Noise Study to systematically reduce the RF Noise level Update Parts 15 and 18 emission rules to reflect broadband noise sources and update emission limits to comport with levels easily achievable with current technology Establish rules to permanently authorize AM Synchronous Boosters Study the impacts of GPS Synchronization of all AM stations in the U.S.

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