IEEE Group Recommends Clarifying ‘Harmful Interference’
White paper calls for transparency
July 31, 2012
Institute of Electrical and Electronics says the ambiguity associated with the regulatory definition of radio
frequency interference is an obstacle to investment and innovation. In a
newly released white paper, the IEEE Committee on Communications Policy advises
federal regulators to refine their definition of interference, and to
make their related deliberations more transparent. The paper targets the
National Telecommunications and Information Administration and the Federal
“In the regulatory status quo, the FCC makes determinations of harmful
interference... based on the cryptic definition in its rules, and on vague past
precedents,” the paper states. “In cases involving possible interference to
federal government systems… rules need only be made public just prior to any
FCC decision. In general, there isn’t even agreement, in many cases, on which
past precedents are applicable.”
Current RF rules generally prohibit a new spectrum licensee from creating
“harmful interference” affecting an incumbent. The definition of “harmful
interference” comes from the International Telecommunications Union:
“interference which endangers the functioning of a radio navigation service or
of other safety services, or seriously degrades, obstructs, or repeatedly
interrupts a radio communication service operating in accordance with ITU Radio
The white paper, entitled, “Clarifying
Harmful Interference Will Facilitate Wireless Innovation,” says this “conflict
between the interests of incumbents and innovators explains the difficulty regulators
often have in devising a regime in a way that pleases all parties involved to
address the overall public interest.”
LightSquared was mentioned as an example of this type of conflict. LightSquared
proposed creating a terrestrial 4G wireless broadband network in L-band
spectrum dedicated for mobile satellite service, and received a conditional
waiver from the FCC to do so. The condition was, that LightSquared’s network
would not interfere with global positioning systems in an adjacent spectrum band.
Interference was demonstrated, however, and the waiver was rescinded.
LightSquared, privately funded to the tune of $3 billion through New York-based
hedge fund Harbinger Capital, filed for bankruptcy in May.
The authors of the white paper, including spectrum policy consultant Michael J.
Marcus, took the NTIA to task for the way it handled LightSquared. Marcus
followed the controversy in his industry blog.
In the white paper, he and his co-authors charge the NTIA with giving “due
deference” in the LightSquared/GPS deliberation to the Executive Steering
Committee of the Interagency National Executive Committee for Space-Based Positioning,
Navigation and Timing, or EXCOM. “… a group which, unlike FCC and NTIA, has no
statutory charter in spectrum management. The FCC has not sought input from its
Technical Advisory Council, and NTIA has not sought input from its Commerce
Spectrum Management Advisory Committee in this matter or any other harmful
The paper further notes that the NTIA set out to identify interference
protection criteria (IPC) for wireless systems in a two-part study commenced in
2003 for President George W. Bush. The first part
was to review and identify current policy; the second was to make
recommendations to refine and improve IPC policy.
“In the six years since the Phase I Report, NTIA has never produced the Phase
II Report, probably because it underestimated the complexity of this use and
its implications,” the white paper states.
The document also discusses key technical issues such as IPC at the receiver, power
flux density at the antenna, propagation models and others. It says, for
example that receiver interference metrics are relatively well established for
digital television at around a -6 to -10 dB interference-to-noise power ratio. The
ITU recommends that total interference from all emission sources to a DTV
receiver not exceed 10 percent of its total noise power. The paper’s authors recommend
that this 10 percent criterion “be used as a starting point for determining
what clarification on interference/signal protection is appropriate for TV
broadcasting, subject to FCC jurisdiction.”
With 2G and 3D cellular systems, the I/S determination is more complex because
it depends on cell site capacity, the authors say. The FCC proposed using a
system based on interference temperature, but it was shot down by the wireless
industry. On the subject of antennas, the paper says newer multiple
input/output technology—MIMO—will figure significantly in the future because of
its ability to reject undesired signals.
“Any harmful interference regime will have to consider how much to budget for
I/S reduction attributable to the antenna system,” the white paper states.
As for propagation models, the paper notes that the disparity between types of
radio systems makes accurate prediction difficult—perhaps to the benefit of
“It seems realistic harmful interference determinations will depend on
realistic propagation modeling—something that some segments of the wireless
community would like to avoid, if traditional models give them a better position,”
the paper states.
Minimum coupling loss and stochastic modeling are also addressed. Determining
interference using MCL defaults to a worst-case scenario and therefore favors
incumbents, the paper said. It recommends that the FCC establish a clear policy
on using MCL or stochastic modeling, as well as minimum protection distances
between transmitters and receivers.
The authors conclude that establishing the type of interference protection criteria
necessary to attract investment will take more than the usual FCC rulemaking
cycle. It suggests the agency consult with the National Academy of Sciences and
the National Research Council, as it did to resolve satellite and terrestrial
use of the C-band in the 1970s. Another possibility is having the president
appoint a “Blue Ribbon Commission” on spectrum reform.
“This type of bold step may be necessary to break from the past deadlock,” the
paper says. ~ Deborah D. McAdams
May 14, 2012: “LightSquared
Files for Bankruptcy”
LightSquared has filed for Chapter 11 bankruptcy in
Manhattan, listing more than $1 billion in debts and in assets. The company
said it filed voluntarily to give itself “time to resolve regulatory issues
that have prevented it from building its coast-to-coast integrated satellite 4G