TR Daily TAC Lays Out FCC Recommendations
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Tuesday, December 1, 2020

TAC Lays Out FCC Recommendations

In the final meeting under its current two-year charter, the FCC’s Technological Advisory Council today heard presentations from its four working groups on recommendations dealing with artificial intelligence (AI), unlicensed operations, 5G radio access networks (RANs), and the Internet of things (IoT).

There were no votes at today’s virtual meeting as the recommendations had been previously approved.

FCC Chairman Ajit Pai credited the TAC with having "yet another productive year," and praised the group for completing its work during the coronavirus pandemic and other challenges.

Mr. Pai also highlighted several of the FCC’s efforts to make spectrum available for 5G, including the planned start next week of the FCC’s auction of C-band spectrum.

"We’re doing all of this on an accelerated time frame that was thought unthinkable just a year or two ago," Mr. Pai said.

In addition, he noted the FCC completed the Citizens Broadband Radio Service (CBRS) spectrum auction earlier this year and last month adopted a plan to allow unlicensed use of the 5.9 GHz band.

"This was an old chestnut that had been sitting around and we finally decided to crack it," Mr. Pai said, adding: "We threaded a needle in a way that I think was thoughtful and allowed everyone to come away with a win."

Those initiatives and others, he said, have relied on the "heavy-duty intellectual foundation that [the TAC ] helped to build. And they proved that your recommendations don’t sit on a shelf. They don’t gather dust. At least that’s not the way I’ve viewed it at all. We take your work very seriously and incorporate it into our decision-making."

The AI WG made five recommendations, including that the FCC should "unlock transformational change" by incorporating AI into its strategic plans.

AI should be "framed to address the important priorities the FCC sees in its mission" and the value AI, as well as machine learning (ML), can have in helping accomplish things such as closing the digital divide and promoting innovation, the WG said.

To that end, the FCC should establish a task force to identify relevant policy areas and dedicate the resources needed—including specialized facilities, human resources, and partnerships—to "expertly analyze and implement policies for the creation of value through AI/ML," the WG said.

Among other things, the task force could examine how AI/ML could be used to augment the FCC’s policies for protecting consumer and public safety and reforming FCC processes, it said.

The WG’s second recommendation was to create a task force to address how the FCC can "best address important aspects of data governance and curation of AI/ML applications to service its internal needs, and those of industry and the public."

The objective for that task force would be to "create data governance, operations, and policy procedures to improve the collection and curation of existing and future data sets to service the internal needs of the FCC, other government entities, industry, the research community, and the public," the WG said.

The task force should include FCC staff with technical training in computer and data science and engineering, as well as similarly trained employees from other government agencies, the WG said.

The task force should complete its work within one year and submit a report to the Commission, the WG recommended.

Among its efforts, the task force should explore "approaches and mechanisms that promote the sharing of data and AI/ML models across the telecommunications industry to extract value from application of AI in solving common technical and operational problems and to address important national economic and societal needs," the WG said.

The task force should also "consider the role that the FCC may play in providing the pre-competitive research community with access to specific curated AI/ML oriented data sets that are important to innovation, technology advances, and the leadership position of the U.S. in telecommunications," the WG said.

The WG also recommended developing a plan and strategy for using AI for "designing, developing, deploying, operating, and maintaining a broadband map that takes advantage of the best technologies and capabilities available."

The FCC should "develop a holistic approach and plan to justify the requirements for the National Broadband Map, including issuing an RFI that provides it with the necessary information to choose a procurement approach that best fits the FCC’s mandates," the WG said.

The WG also recommended the FCC establish policies and approaches to ensure the "safe use" of AI "as it impacts the nation’s networks, communications, and important applications."

The FCC should "encourage and incentivize" operators and their suppliers to institute processes to manage their AI/ML supply chain and track the provenance of models and training data used in their networks, the WG said.

The Commission should also encourage and incentivize operators to disclose the framework they use to analyze and address the vulnerability to, and robustness of, AI/ML models "whose failures could jeopardize the operation of significant portions of the network," the WG said.

The recommendation also called on the FCC to encourage the creation of a consortium to develop one or more common assessment frameworks for analyzing security of AI/ML and for sharing "critical operational vulnerabilities and lessons learned," the WG said.

The Commission should also conduct pilot projects to examine and develop ways of "extracting value from artificial intelligence in solving issues and problems that come before the FCC," the WG recommended.

The WG on the future of unlicensed operations recommended the FCC not change its current approach of favoring "tailored operations and emissions limits" for unlicensed spectrum use and continue to "establish technical parameters with minimal regulator constraints."

The unlicensed operations WG suggested that the "least technical regulations" possible be applied, while still protecting incumbents from interference.

"The FCC should continue in its light-touch approach to unlicensed spectrum and allow industry to collaborate to determine the best methods for sharing the airwaves," the WG said. "The FCC should avoid further codifying standards in regulation, and allow industry to define technical specifications."

The FCC should also initiate a rulemaking proceeding to examine the 60 GHz rules to address issues raised by waiver requests for field disturbance systems, the WG said.

That rulemaking should include addressing power levels for radar applications and coexistence mechanisms, including duty cycle requirements and contention-based protocols, the WG said.

The rulemaking should also determine whether the FCC should allow greater radiated power for radar applications than currently permitted, as well as whether radar applications that perform listen-before-talk (LBT) functions be allowed to use the same power levels as communications systems using the 60 GHz band, the WG said.

The WG’s recommendations also included calling for the FCC to create a TAC working group next year to specifically explore spectrum sharing.

That WG should examine the sharing approaches the FCC currently uses, as well as how well spectrum sharing has worked in the marketplace and how to improve them.

The spectrum sharing WG should also be charged, among other things, with identifying future opportunities suitable for spectrum sharing, the unlicensed operations WG said.

"[S]haring technologies have the potential to unlock large swaths of spectrum for public use," the WG said. "What is clear is that there are many ‘tools in the tool belt’ for sharing spectrum and that there must be careful alignment between technologies, incumbents, and use cases. With several sharing technologies and commercial deployments under development in 2020/2021, further study is needed and the FCC should dedicate a TAC working group to focus on spectrum sharing in 2021."

The recommendations from the WG on 5G open radio access networks (open RAN or O-RAN) included urging the FCC to adopt best practices for new spectrum licensees and incumbent operators.

For new licensees, the FCC should incorporate "mandated PFD [power flux density] limits into network designs to adequately protect incumbent earth station receivers and consider using external transmitter filters to reduce [out-of-band emissions] and subsequently, the allowable distance to incumbent receivers."

For incumbent operators, the FCC should require them to provide "best available deployment information" about their typical deployments to new licensees, the open RAN WG said.

The WG recommended developing and following "processes to resolve performance degradation" at antenna sites and elimination of non-5G sources before identifying potential 5G sources of interference.

Regarding coexistence with bands adjacent to the C-band, the WG recommended partial time division duplex synchronization guidelines that consider all the tradeoffs and global comparisons, along with 4G LTE and 5G technologies, offer an opportunity for coordination.

The open RAN WG also recommended that for equipment authorization, that instead of only using effective isotropic radiated power [EIRP] to determine possible interference, the Commission should examine adding field strength limits for certification of advanced antenna systems (AAS). But older systems could be tested with either field strength or EIRP, the WG said.

The WG also recommended that no changes be made to the FCC’s existing antenna testing protocols because they "correctly specify testing requirements for Advanced Antenna Systems and do not require more testing than is necessary, given the FCC’s light-touch regulatory approach."

The WG also recommended the FCC undertake future study of whether spectrum efficiency could be improved by "measurement of power flux densities over a probabilistic 3D pattern, across multiple frequencies."

The availability of that data in a frequency sharing database could allow for more densely spaced transmitters and help efforts to address active interference management, the WG said.

In addition, the FCC should "explore and evaluate" the impact of power control on out-of-band emissions on user equipment, the WG said.

"[C]urrent evaluations are made at the worst case, highest power levels, which may overstate the out-of-band behavior of the device," the WG said.

Regarding active interference management, the WG recommended the FCC study the optional use for AAS of averaged radiated measurements for interference susceptibility.

It also recommended multi-stakeholder studies on application of "properly averaged radiated power measurements for coverage/compatibility analysis," including whether total radiated power (TRP) offers adequate representation of average radiated power in-band and out-of-band, among other things.

The FCC should also pursue a study to examine whether for the purposes of spectrum sharing coexistence regimes whether using RF fingerprinting or explicit transmission (Tx) identifiers is the best way to identify transmissions, the WG said.

The Commission should work with industry, standards organizations, academia, and federal agencies to determine effective ways to identify transmitters for interference mitigation purposes, the WG said.

In addition, the WG recommended the FCC form a "multi-stakeholder expert technical group" to study inter-system active interference management potential, as well as "encourage and build … broad industry interest and engagement in research programs pursuing data-driven propagation modeling."

The recommendations from the WG on 5G, IoT, and O-RAN included calling on the FCC to support interoperability and encourage acceleration of O-RAN adoption.

The FCC should also support "open" research and development opportunities related to 5G and 6G technologies, including through public-private events and testing in existing 5G testbeds, the WG said.

The Commission should also seek to increase awareness of the differences between the deployment timelines for new entrants and incumbents, the WG said.

Pointing to the need for reliability of the power grid for 5G services and architecture, the WG recommended the FCC continue to make reliability a key focus of the working group next year, as well as continue to work with operators, emergency agencies, and others.

The WG’s recommendations regarding 6G included calling on the FCC to create a national road map that would encourage industry engagement, research and development, and standards setting.

Regarding spectrum sharing, the WG recommended that the FCC consider allowing shared use of spectrum where it can be based on a "data intense/intelligence sharing model."

The Commission should also explore making spectrum sharing in smaller geographies, for example smaller than licenses based on county, the WG said.

Among other things, the FCC should also consider spectrum sharing via non-exclusive licenses, the WG said.

The recommendations for IoT included that the FCC consider making spectrum available for private networks in specific spaces and uses, such as for campuses, transportation, and office buildings.

The FCC should also set specific rules about power levels and shielding requirements, among other things, the WG said. —Jeff Williams

MainStory: FederalNews FCC SpectrumAllocation InternetIoT

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