The following slides summarize proposedresponses toNTIAquestions that have beenprepared by the Subcommittee. CSMAC membercomments are solicited. Introduction The Subcommittee has met on three occasions craftingresponses to the NTIA questions – principal draftingresponsibility for individual questions were assigned toteams of Subcommittee members Complete draft responses, as available, are providedseparately On September 23, the Subcommittee met with theleadership of the FCC Enforcement Bureau (EB) - the EBis fully aware of its future challenges and is preparing toaddress them through a variety of means Question 1 In a shared spectrum environment involving both federal and non-federalusers, what types of sharing criteria would need to be specified in the FCC’s exante regulations, and what can be subject to post-rulemaking/post auctionnegotiated coordination agreements or other sharing arrangements? Assumption - the FCC and NTIA shall identify and report within theex anterules,the majority of the operational and technical rules governing thesharing of Federal Government spectrum, including interference mitigationand enforcement processes, to provide abundant clarity for incumbent FederalGovernment users and prospective commerical operators in advance of thecommencement of any competitive bidding action. Authors of Draft Response - Mark Crosby and Audrey Allison Question 1 – Response Summary Critical Subjects Incumbent Reconfiguration/Expansion RightsDefinition of Exclusion, Coordination and/or dynamic sharing zonesSpectrum Access/Occupancy RightsInterference Limits/TolerancesUse/Powers of a SASEquipment StandardsDispute Resolution ProcessesDefinitions of unacceptable interference levels (Harms Claim Thresholds) Question 2 How would negotiated coordination agreements or othersharing arrangements be enforced and by whom? Authors of Draft Response – David Donovan and Jennifer Warren Question 2 – Response Summary NTIA & FCC have jurisdictional boundaries -Requirement for coordination and planning (47 U.S.C.§ 922& FCC /NTIA MOU in 2003)-Do not contemplate enforcement in the dynamic sharingExploring a revised two-tiered MOU approach -Overarching MOU between FCC/NTIA outlines enforcementprocess to be followed-Specific MOUs between federal/commercial end usersSignificant issues remain -Elements of MOU, e.g. arbitration, fast track interference resolution, dispute resolution process, appeals process etc…-Aspects of this issue have been addressed in some recent FCC proceedings – further research under way Question 3 In a shared spectrum environment where many consumershave widespread access, what additional tools do the FCCand NTIA need to ensure compliance with sharing criteriaor arrangements? Author of Draft Response – Mariam Sorond Question 3 – Response Summary NTIA & FCC have existing tools in place, first these must be identified-NTIA is looking at the possibility to provide additional information regarding the existingtools In general … –Receivers must be capable of measuring the aggregated received signal from other users, withfurther capability of isolating the individual interference source.–Interference criteria and the resolution agreement must be identified with the NTIA and FCC,then the appropriate software and hardware tools would be customized based on agreements.–Meaningful device type-acceptance processes need to be developed to ensure devices arecapable of following the sharing protocols, including switching and shut downs.–Technical response teams are required– Reasonable staff and hours to support field initiatives–Sophisticated tools are needed that could fine tune coordination/exclusion zones, as opposedto the conventional use of radii based on theoretical assumptions. Question 4 How can service providers, federal users andregulators quickly identify and stop harmfulinterference as quickly as possible? Author of Draft Response – Tom Dombrowski Question 4 – Response Summary Prevention, adjudication and enforcement are the key pillars to controlling theinterference environment There is a need for not only the Federal government but also commercialparties to play a fundamental role in interference resolution Potential recommended areas for further study include: –Define harmful interference–Create an unique identifier–Additional spectrum monitoring by all parties–Privatize enforcement of interference issues–Update equipment certification–Ensure transparency and sharing of interference data–Enact special measures to combat bad actors and industrial users ofspectrum Question 5 How should NTIA and the FCC identify and rectifyharmful interference resulting from an aggregate ofoperations from multiple co-channel and out-of-bandemitters? Authors of Draft Response – Dale Hatfield and Dennis Roberson Question 5 – Response Summary Approach Taken: Create a “Straw-man” Enforcement Proposal-Designed to stimulate discussion, thus: Certain aspects of t