Comments to the FCC Regarding Efficient Use of Spectrum Through Improved Receiver Interference Immunity Performance
Introduction and Summary
The Federal Communications Commission (“FCC” or “Commission”) has promulgated a Notice of Inquiry (“NOI” or “Notice”) regarding receiver interference immunity performance as it relates to spectrum efficiency. The Information Technology and Innovation Foundation (“ITIF”) appreciates this opportunity to reply to comments regarding the Commission’s efforts to ensure productive use of spectrum.
As radio frequencies become more crowded, the performance of receivers is a bottleneck for wireless productivity. As recent disputes have made clear, disagreements about whether harmful interference will occur and how the Commission should react to potential interference have sowed controversy and stymied the flow of spectrum usage rights to their most productive uses. Therefore, the NOI is timely and important, and the Commission should take the steps necessary to improve the interference immunity performance of receivers. In practice, however, this goal will not be achieved by direct regulation of design or technical standards for receivers across the board. Rather, the Commission should incentivize voluntary, industry-led standards and take a forward-looking approach to the future interference environment by establishing a clear framework for adjudicating interference claims in the face of differential receiver quality. Key to this is facilitating transparency and collaboration among voluntary standards-setting bodies.