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Dear 802.18 members,cc. 802.11 and 802.15 members,Subject to the decision of the FCC Open Commissions Meeting on 21 April 2022, FCC launches a proceeding to improve receiver performance.The notice of inquiry, ET Docket No. 22-137, "Promoting Efficient Use of Spectrum through Improved Receiver Interference Immunity Performance" is available to download at:There is no deadline on comment submission and reply comment yet as this NOI is yet to be posted to the Federal Register but please note the following as shown in page 2 of the document:Comment Date: 45 days following publication in the Federal Register
Reply Comment Date: 75 days following publication in the Federal RegisterThe following is a short summary of this 51-page document based on my quick review:1) Introduction (Paragraphs 1 - 3)
a) Paragraph 2: "We seek through this Notice of Inquiry to develop an up-to-date record on the role of receivers in spectrum management and how we might best promote improvements in receiver interference immunity performance that would serve the public interest."
b) Paragraph 3: "In this important first step we seek to compile a comprehensive record on the various issues that the Commission should consider, inviting broad comment from all stakeholders as we consider these issues.
2) Background (Paragraphs 4 - 32)
a) Paragraphs 4 - 6: Background on the 2003 NOI and the recommendation being made in 2007 that , with the passage of time, the record had become outdated and that, to the extent that receiver interference immunity performance specifications are desirable, they could be addressed in proceedings that are frequency band or service specific.
b) Paragraphs 7 - 16: Provide some examples on receiver performance specifications that are either frequency band or service specific. Note that none of the examples are related to unlicensed bands.
c) Paragraphs 17 - 18: Mention two recent proceedings that the receiver interference immunity performance associated with incumbent services operating in spectral proximity to new users or services has been a major consideration.
d) Paragraphs 19 - 24: Provide background information on related White Paper and Workshops from Technological Advisory Council (TAC) between 2011 and 2015.
e) Paragraphs 25 - 31: Provide background information on other domestic studies between 2003 and 2013.
f) Paragraph 32 : International development, mentioning ITU, EU, and UK Ofcom.
3) Main discussion (Paragraphs 33 - 171)
a) Paragraphs 34 - 36: Mentioning the Critical Role of Receiver Performance in spectrum management; emphasizing that the role of both transmitters AND receivers is even more important today than in the past.
b) Paragraph 37 - 171: Considerations for Promoting Receiver Interference Immunity Performance
Note paragraph 45 on a question to SDOs: "Are there any industry standards for these types of measurements, created by standardization bodies such as ANSI, IEEE, 3GPP, or ETSI that could be helpful as we consider various approaches for promoting receiver performance?"
Note paragraph 78: "We inquire about whether and how to factor receiver interference immunity performance into spectrum policy in the form of incentives, guidelines, or regulatory requirements. These could include industry-led voluntary approaches, such as industry-developed guidelines and standards."
Note paragraphs 80 to 92 on the Commission's asks to provide comments on industry-led voluntary approaches (including standards and guidelines)
Note paragraph 117 "We also ask whether there are other models that the Commission could draw from as it considers a policy statement. For instance, would ITU Radio Regulations (RR) or relevant ITU-R publications (e.g., ITU-R recommendations) that pertain to receiver performance (along with transmitter performance) provide a useful framework or particular language for consideration?" and "Similarly, would the European Union Radio Equipment Directive provide useful guidance?"
Note paragraph 130 "Similarly, how can industry standards processes be leveraged to provide for improved receiver performance to support a harm claim threshold approach?"
Note paragraph 151 "We also invite comment on the adoption of regulatory requirements or rules (including standards) that require minimal levels of receiver interference immunity performance as the means for achieving the Commission’s public interest goals."Please let me know if you are interested in preparing a response for our members to review.Regards,
Edward
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