April 14, 2017–The Association of Federal Communications Consulting Engineers is warning the FCC that licensed and unlicensed wireless services are “entering a ‘world of pain’ due to increasing levels of radiofrequency noise.” In an ex parte filing yesterday in ET docket 16-191 reporting on a meeting with FCC Chairman Ajit Pai and an aide, the group said it “urged Chairman Pai to direct the FCC’s Technological Advisory Council (‘TAC’) to prioritize development of actionable recommendations to address this issue.”
“AFCCE summarized the comments submitted to the TAC’s inquiry on RF Noise (ET Docket 16-191) [TR Daily, Aug. 12, 2016], explaining that commenters identified a small number of noise sources as culprits and that those same sources were similarly identified by independent research at the ITU,” the filing said. “Two solutions to the noise problem are (1) to increase power to overcome noise and (2) to reduce the level of the noise itself. AFCCE explained that increasing power actually increases noise levels, and devices comprising the so-called ‘Internet of Things’ (‘IoT’) will likely have little or no ability to increase power. In short, if the noise situation is not addressed the highly-anticipated IoT may fall well short of expectations. The FCC last examined its Part 15 and 18 emission limits in 1985 and the underlying limits date from years earlier.
“AFCCE also expressed concern that lack of adequate technical rule enforcement is leading to both increased unlicensed operations and increasingly non-compliant operations, both of which frustrate rule-abiding operators and challenge the ability to share spectrum,” the filing added. “As Lawrence Strickling, former head of NTIA, said in 2015, ‘without adequate enforcement, it won’t matter how much spectrum we make available for sharing.’ AFCCE urged the Commission to expedite its promised online interference complaint portals and re-establish programs of random inspections and post-marketing sampling and measurements to assess and monitor the state of compliance. The FCC’s Sampling and Measurement Branch (in OET) became Auditing and Compliance Branch about 2004 and was eliminated about 2011. In the past, the FCC provided a handbook on troubleshooting interference. However, this handbook has not been updated in more than 20 years and does not include the noise contributors discussed herein. AFCCE also urges the FCC to update this book.” —Paul Kirby, firstname.lastname@example.org