Harm claim thresholds could help sharing in the 3.5 GHz band

I have filed comments on the FCC's proposed new rules for the 3550-3650 MHz band (proceeding 12-354).



My filing argues that explicitly defining the rights of receiving systems to protection from harmful interference lies at the heart of this proceeding; the Notice of Proposed Rulemaking treated receivers as an after-thought, not mentioning them until paragraph 141.

It describes how harm claim thresholds can be used to establish and enforce the interference protection of incumbent services. In similar way, they provide a transparent way to protect Priority Access users from General Authorized Access (GAA) users, and to coordinate the operation of GAA devices.

Harm claim thresholds are the interfering signal levels that must be exceeded before a service can claim harmful interference. While they are used to include receivers in spectrum management, harm claim thresholds are not receiver standards or receiver performance mandates: operators are free to determine how to build and deploy receiving systems that can tolerate allowed interfering signals. 

To follow the development of the ideas, start with blog post. For a recent treatment, see this paper: http://ssrn.com/abstract=2195330. The FCC TAC receiver working group has recommended the use of this approach in a recent white paper.

The filing recommends that harm claim thresholds should be developed using a multi-stakeholder process, but that the resulting values should be included in service rules.

 It argues that harm claim thresholds will facilitate the enforcement of interference protection rights, and contends that this approach is less opaque, rigid and economically inefficient than the status quo alternative.