Steven J. Crowley, P.E.
With praise for academia, the FCC has adopted a Notice of Proposed Rulemaking (NPRM) that would make it easier for colleges, universities, and non-profit labs to conduct radio experiments. The proposed rules create a “program experimental radio license” that lets those institutions apply for broad, long-term, blanket licenses that reduce the need to go to the FCC for each and every experiment. Licensees would instead give seven days’ notice of new operations to the FCC and to the public via an FCC website. Potential interference victims could object before or after the experiment starts, but the burden of proof is on them. Licensees would agree to keep interfering signals on their property. Find something interesting during the experiment that makes you want to try a new frequency? Submit a new notice. It’s a streamlined process that will reduce licensing delays and speed up academic R&D. To get this efficiency, however, interference policing shifts from the FCC to potential interference victims; they’ll have to be on heightened alert.
Entities eligible for the program license do not include industry, which would operate under a conventional license obtained under procedures much like today’s. Compared with the program license, those procedures will take longer and require more applications (and filing fees) to the FCC.
The NPRM doesn’t say why the wireless industry would be excluded from program license eligibility; moreover, it says little about wireless industry R&D. Academia, however, is described as “a powerhouse for ideas that fuel major advances in communications and propel both fundamental research and applied development.” We read that colleges, universities, and non-profit labs “typically have a record of generating the types of innovations and technological breakthroughs we seek to foster,” without learning what those types are or how the private sector is unable to similarly innovate. We read further about the “unique abilities of universities and research institutions to act as trusted stewards of the radio resource” without being told what those unique abilities are and why industry cannot be trusted.
I join in praising academia; it deserves the relief it will get in the new rules. But the U.S. wireless industry deserves equitable treatment for its equally important R&D programs. If for nothing else, academic and corporate research is increasingly conducted jointly, and there’s a practical matter of coordinating corporate and academic research schedules. If the company is on a slower timeline for FCC approval, that timeline will drive the joint research.
Industry should file comments with the FCC, through trade associations, standards bodies, and individual companies, asking to be included among entities eligible for the program experimental license. The FCC says it will entertain proposals to broaden the scope of eligible institutions, if such a proposal shows how it “more effectively balances the interests at stake.” Some of those interests are “economic growth, global competitiveness, and a better way of life for all Americans.” There is nothing competitive about, and no growth in, a new discovery until a company takes it and combines it with labor, capital, and tools of productivity to produce goods and services. In wireless, part of this industrial development often involves placing a device on the air for testing. Today, 9 out of 10 of applications for new experimental licenses are from industry. Streamlining the experimental application process is a productivity improvement, and such improvements in productivity are a straight multiplier to economic output.
There is more to the proposed rules than the proposed program license. Medical institutions would find it easier to conduct experiments, opportunities for market trials would be increased, and “innovation zones” –
in which industry could participate – would make large-scale experiments easier. Conventional (current) experimental rules remain in place, with some streamlining. The FCC asks 96 questions seeking advice. If you have an interest in experimental radio work, read the NPRM, answer any questions you can, and offer your comments to the FCC.
The U.S. wireless industry has a great R&D story: products, services, patents, expenditures, jobs, collaborations. Tell the FCC yours.