Letter to Alan Davidson, Assistant Secretary of Commerce for Communications and Information, Arati Prabhakar, Director of the Office of Science and Technology Policy, Robin Carnahan, Administrator of the General Service Administration - Matsui and Guthrie Urge Biden Administration to Review Federal Receiver Technology


Date: Oct. 27, 2022
Location: Washington, DC

Dear Assistant Secretary Davidson, Director Prabhakar, and Administrator Carnahan:

Demand for spectrum is increasing at an unprecedented pace. For the United States to remain the leader in wireless communications technology, more intensive use of spectrum will be necessary. Federal systems will play a significant role in helping or hindering this goal and we urge you to initiate a comprehensive assessment of federal receiver technology and policies to support a more dynamic spectrum environment.

Spectrum use patterns are rapidly evolving and it is imperative that government systems keep pace to support this innovation. New sharing techniques and more flexible, market-oriented approaches to licensing are creating new opportunities to serve consumers and meet business needs. Despite these advances, there have been several examples of receivers preventing or slowing more productive uses of spectrum. While federal spectrum management has traditionally scrutinized transmitters, power levels, in-band and out of-band emission limits, among other issues, it is clear receiver performance is also a critical component of effective spectrum environments. The Federal Communications Commission (FCC) recently initiated a Notice of Inquiry (NOI) to examine "role of receiver performance in our spectrum management responsibilities, with the goal of facilitating new opportunities for use of our nation's spectrum resources." To better understand how federal systems' receiver performance impacts this goal, we believe a similar effort must be undertaken across the federal government.

Given the increased demand on national spectrum resources, some new spectrum deployments will involve Federal and non-Federal governance. In these cases, legacy government systems with poor receiver performance could unnecessarily prevent underutilized spectrum from being made available for more efficient use. Additionally, federal procurement and deployment of ineffective receiver technology now could foreclose spectrum innovation in the future. In both scenarios, additional federal scrutiny of receiver technology and procurement policies will help keep our spectrum pipeline healthy.

The FCC's NOI acknowledges that "incorporation of receiver performance specifications could serve to promote more efficient utilization of the spectrum and create opportunities for new and additional use of radio communications by the American public." This same principle holds for federal systems. While overly prescriptive or rigid specifications will likely be counterproductive, understanding how federal agencies measure, analyze, and specify receiver performance across federal systems is an important first step. In its filing to the FCC's NOI, the National Telecommunications and Information Administration (NTIA) notes that its "Institute for Telecommunication Sciences (ITS) has developed a suite of measurement techniques, capabilities, and institutional knowledge to characterize receiver performance of many types of systems." This expertise should be employed across the federal footprint consistent with NTIA's role.

As more federal agencies assess their current and expected future spectrum usage, it is imperative that agencies must also look at ways to improve receiver performance. NTIA acknowledges in its filing that "various other federal agencies in some cases have their own receiver-focused performance requirements and activities for radio systems that are critical to federal missions." These requirements are foundational to the success of federal missions, and their development and periodic update would benefit from the engineering expertise of ITS.

To help address these important issues, we urge you to initiate a review of federal receiver technology and policies across the federal government. We appreciate your attention to this matter and look forward to working with you to maintain American leadership in wireless communications technology.