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Receiver Immunity Standards Unnecessary, Impractical for Amateur Service:

from The ARRL Letter on July 25, 2013
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Receiver Immunity Standards Unnecessary, Impractical for Amateur Service, ARRL Says:

Responding to an FCC call for comments based in part on recommendations in a Technological Advisory Council (TAC white paper, the ARRL this week told the Commission that establishing so-called "harm claim threshold" (HCT) standards for receivers would not work in the Amateur Service. HCTs, expressed in field strength or power flux density, would specify the level of radio interference that receivers should be expected to tolerate before a radio service could claim harmful interference. Limits would be established throughout a service's assigned frequency range as well as within certain frequencies outside that range. The ARRL argued that there is a need for minimum, perhaps even mandatory, receiver performance standards for home electronic devices, but the Amateur Service should not be subject to receiver immunity standards.

"Any performance standards for Amateur receivers would be purely arbitrary, and would compromise the experimental purposes of the Service," the ARRL told the Commission. "Amateurs have the technical knowledge to differentiate between interference from spurious or out-of-band emissions from nearby transmitters and that caused by receiver deficiencies."

In the Amateur Service, the League continued, station-to-station interference issues are typically resolved cooperatively without FCC intervention and are "essentially not a problem." The issue for radio amateurs, the League said, is "protection from spurious and out-of-band emissions from other services."

Early last year then-FCC Chairman Julius Genachowski tasked the TAC with studying the role of receivers "in ensuring the efficient use of spectrum and to provide recommendations on avoiding obstacles posed by receiver performance to making spectrum available for new services." In late April, the FCC released a Public Notice (ET Docket 13-101, detailing the recommendations of the TAC's working group on receivers and spectrum in a white paper called Interference Limits Policy -- The use of harm claim thresholds to improve the interference tolerance of wireless systems. A General Accountability Office report in February recommended that the FCC "consider small-scale pilot tests and other methods to collect information on the practical effects of various options for improving receiver performance." The FCC accepted comments on both the TAC white paper and the GAO report.

The ARRL told the FCC that the HF environment is not conducive to fixed receiver standards and that it would be impossible to establish reasonable HCTs for HF radio equipment. "The most pressing need," the League said, "is for improved immunity of consumer electronic devices and systems. The Commission has had the authority to require this for many years, and has failed repeatedly to exercise it." Read more


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