[arrl-odv:25567] Technological Advisory Council (TAC) Noise Study, Docket 16-191

Greetings. With authority of the Executive Committee, I have just now filed the attached comments in response to the Public Notice issued by FCC in mid-June concerning a planned study of the radio spectrum noise floor to be conducted by the FCC's Technological Advisory Council (the TAC). Overseeing the study will be our own delegate to the TAC, Greg Lapin, N9GL, who has ably advocated for ARRL for years in this important group, and Lynn Claudy at NAB, who is also very competent. As you will see when you read these comments, the TAC was charged by FCC with doing this noise study in 1999 shortly after it was formed, but it never did one. The current docket proceeding asks for comments on how such a study should be done. These comments provide extensive input on the subject and respond to a series of detailed, multi-part questions on how an accurate and reliable noise study can be completed. We have for years urged FCC to get this data in order to make responsible spectrum management decisions. We have also gotten in a few licks about the enforcement situation with power lines, RF lighting devices, noisy switched power supplies, etc. I am very grateful for the excellent input into these extensive comments (which I think you will find impressive in the technical details) from Ed Hare especially, but also from Mike Gruber, Bob Allison and Kermit Carlson. Thanks also to the Executive Committee and especially President Roderick for extensive editorial assistance with this filing. There is no reply comment period but Ed and the EMC Committee will work directly with Greg Lapin on this on an ongoing basis. No thanks incidentally to the FCC's new, and very defective ECFS 3.0 software and their absolutely useless help desk. I somehow managed to get these filed using an old computer here in the office. Reportedly, FCC's IT staff has been working for days to figure out the glitch that doesn't allow uploading of files of any sort. PDF and WORD versions of the as filed comments are attached. 73, Chris W3KD -- Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG
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Christopher Imlay