“I’m delighted that the Commission has recognized the role of receivers in efficient and resilient radio operations. Its Notice of Inquiry (NOI) about improved receiver interference immunity, and the rulemaking that I hope will follow, gives the U.S. an opportunity to take the lead internationally by shifting the regulatory emphasis from receiver performance standards to describing the interference environment that affected systems should expect to operate in. Such an interference limits approach leaves receiver design to manufacturers and operators, where it belongs.
I’m grateful for the Commission’s recognition of the potential of harm claim thresholds, and particularly Commissioner Simington’s leadership in this area. The NOI builds on Dale Hatfield’s thought leadership over many decades. It reflects the efforts and insight of Commissioners and OET staff over many years, especially in guiding and supporting the extensive work done by the FCC Technological Advisory Committee.
This NOI does not come a moment too soon. For decades there has been chronic conflict between services in adjacent bands over acceptable receiver performance, and it has become acute recently. The time has come to fully include receivers as well as transmitters in the regulatory calculus.
Receiver performance certainly plays a critical role in productive and robust radio use, especially in adjacent bands that support different services. However, it’s difficult and inefficient for third parties to set receiver performance criteria: for a regulator, because it does not have the in-house expertise; and for industry standards groups since they typically reflect the interests of just one side of a contested band edge. The best way to include receivers in the mix is for the FCC to specify the socially optimal interference constraints on the whole transmitter-receiver system.”
