Alhough this is kind of related to the NextNav 900mhz thread currently in play, I'm creating a new thread because this really stands on it's own, and relates directly to Part 15 AM broadcasting - as well as the Part 15 900mHz band -- and I realize I'm the only one who keeps bringing this up, but the responses, what few there have been, never seem to grasp the significance of it in relation to our hobby.
I finally realized that our current primary active posters, at least two or three are Canadian, another in New Zealand therefore of no personal relevance to them (understandably). But keep in mind the CRTC and SOR has always stayed in a kind of unison with the direction and implementation of FCC here in the U S Don't know New Zealand regulations at all. 😁
Well, on second thought let me go on for a minute before I get to what I came to post, what happens with NextNavs proposal is just as relevant to our Part 15 hobby as the AM In Every Car Act is. So I harp on it some more, I'm sure there must be some reading this in the U.S. for which this feels relevant.
Previously @Mark had pointed out that there's no way a 900mHz signal can interfere with our AM broadcast, and I presume that's entirely true, however, the 900mHz house electric meters have a known history of interfering with AM reception - not the meters transmission itself, but from their co-dependant operation with the receivers on the poles. So correct, the 900mHz does not interfere with AM directly, but directly or not, the existence of those 900mHz meters periodically, but consistently interfere and make AM unlistenable.
What NextNav is proposing for 900mHz is much more threatening, not only the plausable potential of interfering with AM due to other operating devices in the meters networks (as illustrated above), but also the bigger threat to abolish all protections on the Part 15 900mHz band, the ONLY Part 15 band that's ever been protected from interference. Just do away with it.
Ok, enough about NextNav, I almost forgot what I came to post..
Taking a look at an excerpt(s) from a J.H. Snider Whitepaper on the topic, after which a brief introduction of Snider himself to give a better perspective on the the time frame and reliability of his research and what he has to say. ....
Spectrum Policy Wonderland
A Critique of Conventional Property Rights and Commons Theory in a World of Low Power Wireless Devices
Prepared for delivery at the Telecommunications Policy Research Conference George Mason University School of Law, Arlington, VA September 30, 2006.
Excerpts from pages 32 and 33
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As a general rule, unlicensed devices authorized by the FCC are expected to be secondary to licensed devices. In practice, as a result of trespass laws, they need not be. But trespass laws are not within the FCC’s jurisdiction.
The one little known exception where unlicensed devices are not secondary to licensed devices is in the 900 MHz band, widely used for cordless phones, baby monitors, and other simple indoor unlicensed devices.
The 900 MHz exception occurred because of a historical anomaly. Unlicensed devices were authorized first in this band and licensed services only later. Following its normal practice of protecting incumbents against newcomers, the FCC granted the unlicensed incumbents safe harbor protections against the licensed newcomers. The FCC also granted licenses only for a narrow outdoor use--vehicle monitoring--whereas the unlicensed devices were only protected for indoor use.
More recently, the FCC has sought to extend the use of unlicensed underlays through what it called the “interference temperature” concept. This was a klutzy, property independent conceptualization of unlicensed service that was in keeping with the regnant unlicensed commons approach but which was also deeply muddled and went down in fiery defeat because no one could figure out a compelling way to make it work. A better approach might have been to develop an interference temperature metric with respect to tangible property rights.
Unfortunately, the technical details of such underlay interference management schemes as “interference temperature thresholds” are far beyond my intellectual grasp. The central point I want to make is that, as with any property model, spectrum emissions should be limited at the property line. What is done within those property lines is of no concern to the government unless there is an impact on those with property rights outside those lines, in which case a balancing act must be conducted. That balancing act is a staple of American jurisprudence because human activities in the real world rarely are
purely self-contained within property lines.
On my property, for example, the leaves
from my trees fall on my neighbor’s yard, the water from my yard traverses into my
neighbor’s yard, and my kids’ playing makes noise that my neighbor can hear. The task is to use common sense reasoning to balance my neighbor’s property rights with mine, and the same can be done with spectrum underlays.
In conducting this balancing act, underlay rights should be given the benefit of the doubt over overlay rights, something that is completely contrary to the current spectrum management regime. Overlay rights should not be ignored but when they conflict at the margin, first priority should be given to underlay rights. This, of course, is standard procedure when the government conducts any other type of eminent domain action. Spectrum should not be the lone exception.
The Communications Act of 1934 grants the federal government the authority to
transition from the current system to the system I propose. Under the Communications Act, no licensee can have ownership rights to spectrum. All the licenses, even those acquired at auction, are for a limited duration of years. If the government wants to reallocate spectrum and divide overlay from underlay rights or switch entirely from a licensed to unlicensed property rights regime, it can legally do so.
Even within the license terms of most licensees, the government has the right to separate underlay from overlay rights. In some cases, the disposition of underlay rights is unclear. But in many cases, they have clearly not been allocated as part of a license. ... ... ..
Broadcasters, of course, want those underlay rights for themselves and will fight tooth and nail against anyone else getting them. Indeed, broadcast licensees have instigated a proceeding at the FCC that, by giving them geographic service area rather that site based rights, will put them well on the road to getting such underlay rights. But the FCC is currently under no legal obligation to give
broadcasters such rights.
With privileges, of course, come responsibilities. Local entities should not only be given far more privileges to use spectrum locally. They also need to be given responsibility for enforcing those rights. The FCC is wholly unsuited to managing the new spectrum world
we are entering. Enforcement of unlicensed property rights should be given over to local governments, which currently enforce other local nuisance and trespass laws and are far better suited than the FCC to enforce violations of unlicensed property rights. .... .... .. ..
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Just so you know, J.G. Snider (Phd) has lots of credits behind him, but here is just to point out he had been heavily involved, well regarded and provider of valuable input directly affecting the directions of the FCCs Part 15 restructure in 1996. His name found cited everywhere in regard to those FCC modifications of the Part 15 rules.
To help me better introduce him I simply asked the Google AI "What involvement did J.H. Snider have with FCC during the 1990s?".
Here is a shortened version of it's reply:
James H. ("Jim") Snider is a public policy expert who has written extensively and been cited in various reports and papers relating to telecommunications and spectrum policy, which are key areas of the FCC's work.
His work in this period focused heavily on the Telecommunications Act of 1996 and the associated policy debates. Key aspects of his involvement include:
... Snider researched the political and economic factors surrounding spectrum management... He was a prominent critic of what he and others termed the "corporate giveaway" of valuable broadcast spectrum to incumbent broadcasters at no charge, a provision within the 1996 Act. The FCC had estimated this spectrum's value at up to $70 billion if auctioned for wireless telephone services.
In essence, Snider was an independent analyst and academic who provided critical analysis and policy recommendations regarding FCC decisions and the broader telecommunications landscape, often advocating for policies that would generate revenue for the public from the use of public assets. "
His relevant experience includes:
Research Director of the Wireless Future Program at the New America Foundation (a public policy institute) from 2001 to 2007.
An Affiliated Researcher at Columbia University's Institute for Tele-Information from 2007 to 2011.
An American Political Science Association Congressional Fellow in Communications and Public Policy from 1999-2000.
He has been quoted as an expert in spectrum policy, with his work estimating the value of spectrum distributed by the U.S. auction system.
In summary, while not an FCC employee, J.H. Snider is a prominent expert whose research and commentary on telecommunications policy are relevant to the FCC's mission and proceedings.
"