The Federal Communications Commission has formally begun a proceeding to gather information about wireless receiver performance, and how it might encourage better performance in wireless receivers—an effort that has bipartisan support on the commission, and which could represent a turning point for the design of wireless systems.
While the FCC is only seeking information to start, the agency made clear that it could take a number of actions to act upon the information it gathers, from incentives or establishing best practices, to regulatory requirements.
The newly issued notice of inquiry seeks information to update the FCC’s understanding of the role of receivers in spectrum management and how the agency “might best promote improvements in receiver interference immunity performance that would serve the public interest.”
In its notice of inquiry, the agency noted that “while the Commission has typically focused its rules on the transmitter side of radio systems, as several recent Commission proceedings have underscored, receivers and receiver interference immunity performance play an increasingly critical role in enabling more efficient spectrum use.”
“Most discussions of spectrum efficiency are a one-way effort. They focus almost exclusively on transmitters,” said FCC Chairwoman Jessica Rosenworcel. “To avoid harmful interference, we typically have rules about how and when transmitters can operate. But wireless communications systems involve transmitters and receivers. It’s a two-way proposition. Both are vital. Both matter. So we need to rethink our approach to spectrum policy and move beyond just transmitters and consider receivers, too.
Rosenworcel added, “Receivers that are not sufficiently resilient can make it more difficult to introduce additional services in the same or adjacent airwaves”—which is exactly the issue that the FCC ran into in the run-up to the activation of C-Band spectrum by AT&T and Verizon, when the Federal Aviation Administration and the aviation industry pushed for the delay and geographical limitation of C-Band deployments due to fears about interference with legacy altimeters; more specifically, that the old and difficult-to-replace altimeters would be impacted because their receivers would be unable to filter out the new, terrestrial C-Band 5G signals. Old receivers, Rosenworcel continued rather pointedly, “can diminish the spectral environment and shut out new uses before they even begin. There is too little in our existing spectrum policies that recognizes this truth. There is also too little that incentivizes users or manufacturers to invest in better quality receivers. But as we expand the use of our airwaves and wrestle with different uses in adjacent spectrum, we need to give consideration to the role of reception technology.”
The Commission gathered similar information in 2003, but the new inquiry will provide an update on new techniques, technologies and research related to receiver performance. Rosenworcel specifically thanked Commissioner Nathan Simington for his contributions to the inquiry; Simington, a Republican, has been a driving force for the consideration of receiver performance metrics—although he has also said that he hopes that ultimately, the mere consideration of regulation by the commission will nudge industry to act on its own to improve receiver performance.
For his part, Simington said in a statement that he believes that the new FCC notice of inquiry (NOI) asks “the critical questions that must be answered if we are to prevent a spectral famine,” including questions that get to the heart of spectrum rights and how spectrum disputes are adjudicated. “It is time that our spectral rights framework becomes certain, and it is time that our regulatory approach goes duplex,” Simington said, going on to add that “FCC spectrum policy must clearly and precisely define spectrum rights, both in-band and at band edges, and those rights must reflect efficient receiver performance where that is a reasonable goal. This is the only framework truly capable of accommodating the interests of not only industry incumbents and future commercial users, but that also stands as a model for federal users.
“As I’ve argued before,” he continued, “we cannot afford the next C-Band fight—wherever in the allocation table it might be. This item takes a first step toward foreclosing that eventuality.”
