On July 26, 2022, JP de Vries, Director Emeritus of the Spectrum Policy Initiative and Distinguished Advisor to Silicon Flatirons, filed reply comments in the Federal Communications Commission’s Notice of Inquiry (NOI) in ET Docket No. 22-137 promoting efficient use of spectrum through improved receiver interference immunity performance.
“There is solid support in the record for further exploration of interference limits and harm claim thresholds (HCTs),” said De Vries. “There is also broad support in the record for the Commission to issue a policy statement that lays out how it will assess compatibility between radio systems.”
“The Commission should pilot interference limits in a limited-scope reallocation or rule change,” he continued. “An interference limit is a metric that can be used to negotiate trade-offs between transmitter and receiver concerns. Once it has developed expertise and confidence, the Commission can move on to using HCTs in technical rules.”
“Most of the fears and reservations about interference limits and HCTs can be filed under ‘Don’t shoot the messenger,’” he pointed out. “These concerns apply just as much to conventional Commission rulemaking as to this new approach”
View the reply comments:
- (pdf) Reply comments of JP de Vries in OET 22-137, July 26, 2022
- (docx) Reply comments of JP de Vries in OET 22-137, July 26, 2022
Related work:
- A presentation to the FCC Technological Advisory Council on interference limits and harm claim thresholds (April 26, 2022)
- Comments on the NOI (June 27, 2022)