Bring the Noise (Floor)

In a little-covered meeting earlier this summer, the FCC’s Technological Advisory Council voted to proceed with what could potentially be a controversial study of noise across the electromagnetic spectrum. This two-page PDF outlines the TAC’s proposal and asks several questions about what such a study should cover, and how to go about doing it.
Many FCC-watchers seem pleasantly surprised that the TAC is wading into this mess. The study itself will be broken down along two lines: attempting to quantify interference from intentional and unintentional radiators. Intentional radiators are sources of potential noise that mean to broadcast — think radio and TV stations, wireless routers, and the like. Unintentional radiators are things that emit RF energy (and potential noise) but that is not their primary reason for being — think most electronic devices, older-model LED systems, and whatnot.
Nearly a year ago, the TAC broached the idea of doing a noise-inventory of the spectrum but backed away from it as seemingly unpalatable. At that meeting, the FCC’s Walter Johnson observed, “People are afraid this is a ‘eating the ocean’ sort of problem, that it cascades into so many different areas with so many issues, that it’s a very big challenge.” What has changed?
Back in 2015, the TAC did submit that, if it did undertake a noise-floor study, it would do so in a “reality-based” fashion. For example, according to the American Radio Relay League’s Greg Lapin, there’s a common presumption that the RF noise floor is rising — but there’s little quantitative study of this, much less an analysis of whether or not rising noise floor(s) have detrimental effects on existing wireless services. But such a study will only have credence if it can be shown to involve objective science…and that’s a hard thing to come by in D.C. environs these days.
The biggest answer, like most things in policy proceedings, is political will. During the FCC’s AM revitalization proceeding, dozens of comments were filed lamenting how the noise floor of the AM band has risen out of control over the last few decades, making it effectively impossible for AM radio listeners to pick up even local stations. And of course there’s been a huge push by some broadcasters to convince the FCC to make unlicensed broadcasting a bigger issue, using the threat of interference from pirate stations as a primary cudgel to advance a pirate crackdown. Considering that broadcasters have been leading the charge to undertake a study such as this one, it’s safe to assume that the broadcast bands will most likely be the primary focus.
Especially since the chair of the TAC subcommittee is an NAB lobbyist. Regardless, the TAC is expected to receive a preliminary report on noise at its December meeting, and you have until August 11th to contribute comments regarding the study’s proposed ground-rules. As of today, only 14 comments have been filed in this proceeding.