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Survey of Review of TDRA Regulations for Interference Management, Spectrum Monitoring and Enforcement
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Name
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Email
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Organization and Position
1. Interference Management Regulations, 2008
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What is your view on combining the two Regulations (Interference management, Spectrum monitoring and enforcement) so that interference management is addressed in all its forms, in one Regulation? Kindly support your response with the pros and cons.
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Do the objects listed in section 2.1 (Interference Management Regulation) cover the full scope of matters the TDRA should take account of in relation to interference?  If not, please provide your suggestions.
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  1. Please indicate which interference issues you consider to be most problematic.
  2. What are the priority cases for interference resolution?
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Do you consider the definition of “harmful” interference as it currently stands in the Spectrum Interference Management Regulations to continue to be appropriate?  If not, provide reasons why not; and/or provide a substitute or amendment to the definition.
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Should additional categories of interference that receive different treatment be included?  If so, please indicate what those might be.  For example, should different categories receive attention but perhaps over a longer timeframe (also see Question 3 in this regard)?
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Sources of interference presents issues that cause the interference. These issues were appropriate and relevant for inclusion in the 2008 Regulation. Are these issues still relevant in your view?  Please give reasons.  If not, please suggest any other issues which you consider should be included.

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Do you have any comments on the procedures for making an interference complaint and the actions taken by the TDRA in response?  When providing your response please indicate if you are an Authorized User and if you have had cause to submit an interference complaint to the TDRA previously, and what your views about the process are.

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To Resolve interference complaints, TDRA proposes to set out the type of violation and possible actions to be taken in one Regulation.  Do you agree with this approach? (also see Question 1 in this regard)?
2. Spectrum Monitoring and Enforcement Regulations, 2008
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Based on the Objectives for monitoring and enforcement listed in section 3.2 of the regulations:

  1. Do you agree with the proposed approach to include a shorter more general list of objectives in the regulations? If you do not agree, please explain why not. 
  2. Are there any additional objectives that you believe should be specified or taken into consideration?
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Do you agree that all regulatory provisions that relate to spectrum monitoring and interference management could be incorporated into one regulation?  If not, please give reasons (also see Questions 1 and 8 in this regard).
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The TDRA’s approach may be to educate the person or entity about the need for type-approval and compliance with the relevant authorization. In case of delays in, or absence of compliance, the TDRA may initiate prosecution.  The outcome will nonetheless be that the source of any interference is removed and that compliance will be achieved. Do you agree with this approach or propose any different approach?
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As the TDRA is also considering creating categories of interference by severity and allocating time to respond accordingly, do you agree that it would be appropriate to match the enforcement action to the severity of the non-compliance?  If you do not agree, please give reasons.
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The TDRA currently issues a “show cause order” under Article 11 of the Spectrum Management and Enforcement Regulations. 

  1. Is a ‘show cause order’ sufficient or should additional administrative tools such as fixed penalties and equipment seizure be considered?
  2. Do you agree with the threshold criteria to be met for a complaint about harmful interference before any action will be taken?
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The TDRA has a number of ways in which it can monitor compliance with authorized parameters in the spectrum authorization and the technical and regulatory conditions in the spectrum regulatory framework. These include spectrum measurements, monitoring, drive tests, inspection of authorized stations, requests for submission of documents, and technical details of the apparatus.  These are consistent with the methods used in other countries. 
  1. Do you consider these activities to be sufficient in relation to monitoring compliance? If not, please advise what you suggest.
  2. If you disagree with the outcome of a TDRA monitoring exercise, how do you currently address this issue with TDRA?
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Do you have any additional issues which you feel are relevant for consideration in this consultation?
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Please provide specific support and/or explanation of your viewpoints as well as recommendations regarding how such issues might be resolved.
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