6/27 FCC Comments Proposing a Standard Receiver Framework to Enable More Spectrum Use

OTI’s Wireless Future Project filed comments with Public Knowledge proposing that the Federal Communications Commission (FCC) adopt a new standard receiver framework that would help to ensure that antiquated or atypically vulnerable receivers in use by incumbent services do not prevent or diminish the FCC’s ability to authorize new spectrum uses either on a shared co-channel basis, or in adjacent bands that could impact incumbent services. The proceeding is a Notice of Inquiry with a stated goal of helping the FCC decide whether and how to begin regulating receiver performance and standards to promote greater spectrum access and efficiency.

In concept, the proposed “standard receiver” framework is simple. The Commission should simply state when it authorizes new spectrum services what the general resistance of the “standard” receiver device for any possibly impacted band should be.

Under the new standard receiver framework, the Commission would provide incumbents in adjacent bands interference protection solely from the OOBE transmitted by any new service. The Commission should determine the permissible OOBE for a new allocation or service based on a combination of the characteristics of already-operating “standard receivers” that could be impacted and reasonable expectations for service performance.

Potential changes in OOBE are the only change in the spectrum environment to which an incumbent licensee should be able to assert any entitlement to protection. Incumbents have no right to “listen” outside their assigned frequencies. Licensees have only the right to transmit on frequencies and at power levels authorized by the Commission, and receivers therefore have no right to protection when they take fail to confine reception to the frequencies authorized by the license.