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SBE Files Comments on RF Noise, Urges Noise Study

August 12, 2016

On June 15, 2016, the FCC released a public notice in ET Docket 16-191 noting that its Technological Advisory Council (TAC), an advisory group to the FCC operating under the Federal Advisory Committee Act, is investigating changes and trends to the radio spectrum noise floor to determine if there is an increasing noise problem, and if so, the scope and quantitative evidence of such problem(s), and how a noise study should be performed. The SBE provided responses to the TAC for its investigation. Further, the SBE provides insight into the scope and quantitative evidence of the problem and shows that a noise study should be performed by the TAC.

The SBE filing is posted online. The SBE states that the noise study has been necessary for well more than two decades. The Commission critically needs at least preliminary results from this study to make time-critical spectrum management decisions. Spectrum planning cannot objectively be done without this noise information and it is unfortunate that the initiative has been delayed this long. The SBE should be considered a willing resource in the TAC effort and we hope to contribute substantially to the effort. The SBE also hopes these comments will serve as a catalyst for a reevaluation of the policies of spectrum enforcement and sanctions against operators of incidental and unintentional radiators, which are causing long-term interference problems, such as power lines. The unwillingness of the Commission to issue meaningful sanctions has led to the virtual absence of any incentive by power utilities to comply with the Commission’s Part 15 non-interference obligations.

The SBE further requests that the TAC focus its attention on a plan to reduce RF noise in at least the medium-wave band. There are other steps that will inevitably improve AM broadcasting, but SBE considers the issues to be addressed by the TAC to be the most urgent of these.

SBE President Jerry Massey, CPBE, 8-VSB, AMD, DRB, CBNT, adds, "The SBE has taken a leading role in addressing the RF noise issue. The SBE-recommended study is extremely important in identifying the obstacles to AM revitalization and interference to FM and OTA television broadcasting. A successful noise study will provide insight as well into the FCC's spectrum planning, and it will provide some desperately needed objectivity in rules governing Part 15 and Part 18 devices and the process of spectrum overlays in the broadcast auxiliary service bands."

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