It appears that many of the links to the FCC EFCS website are no longer valid. I don't know if they archive stuff or not when the NPRM is completed and R&O issued, and if so, I don't know if they are available on-line. If anyone knows how to repair these links, let me know and I'll fix them.
Don't miss the comments of Ben Gelb, KF4KJQ (link at the bottom of the Table of Contents). Ben is a graduating senior from Thomas Jefferson High School for Science and Technology in Alexandria, VA. He will be attending MIT. Ben is not only good at science and technology, he writes pretty well too ... better than most of us, and way better than any of the BPL industry.
ARRL Information
FCC PROPOSES RULES FOR BPL SYSTEMS
ARRL Letter 23-09 02/27/2004
The FCC this week released its Notice of Proposed Rule Making (NPRM) on
Broadband over Power Line (BPL) systems. The 38-page NPRM--in ET Dockets
03-104 and 04-37--proposes amendments to FCC Part 15 rules to define
so-called "access BPL," make rules specific to BPL systems and provide
measurement guidelines for BPL devices and systems. It would make no
changes to Part 15 emission limits for unintentional radiators, however.
ARRL CEO David Sumner, K1ZZ, says that while Part 15's current limits on
unintentional radiators on HF may be appropriate for short-duration,
narrowband emissions, they are inappropriate for the sort of
long-duration, broadband emissions BPL would employ. He compared
short-duration, narrowband emissions at the Part 15 radiated emission
limit to a helicopter flying overhead.
"The noise is deafening, but is tolerable because it doesn't happen very
often nor last very long," he observed. "To a radio user, having BPL in
the neighborhood would be like having the helicopter hovering constantly
overhead."
ARRL Lab Manager Ed Hare, W1RFI, offered an example most hams could relate
to. "The limit for an unintentional emitter on HF is 30 uV/m at 30 meters
from the source," he said. "If you take a dipole cut for 3.5 MHz and put
it in a 30 uV/m field, you'll have a noise reading of S9 plus 16 dB at
your transceiver."
The FCC proposal takes a broader view of interference. "There is
significant disagreement among the commenting parties regarding the
interference potential of Access BPL," the NPRM declares. "Amateur
operators and amateur organizations in general are opposed to Access BPL
and advocate emission limits that are lower than the existing Part 15
limits."
Still, the NPRM concedes, Amateur Radio operations "are likely to present
a difficult challenge in the deployment of Access BPL in cases where
amateurs use high-gain outdoor antennas that are located near power
lines." Noting that power line noise already presents a significant
problem for hams, the FCC said, "we therefore would expect that, in
practice, many amateurs already orient their antennas to minimize the
reception of emissions from nearby electric power lines."
The NPRM goes on to point out that because BPL has the capability to stay
clear of specific frequencies, BPL providers can simply "avoid the use of
amateur frequencies when in close proximity to amateur outdoor antennas."
The NPRM also briefly mentions the possibility of interference to BPL
systems from Amateur Radio, an issue ARRL and others raised in their
comments on last April's Notice of Inquiry on BPL.
The NPRM emphasizes that under the proposed rules, operators of Access BPL
systems would be responsible for eliminating any harmful interference that
may occur. The FCC says it believes current Part 15 emission limits for
carrier current systems--in conjunction with certain additional
requirements specific to Access BPL--"will be adequate to ensure that
existing radio operations are protected against harmful interference."
Sumner suggested that, with licensed services and government users taking
up large portions of the HF spectrum, protecting all licensed HF users
could prove to be a nightmare for BPL providers. He noted, too, that while
the FCC maintains that licensed services must be protected, the proposed
rules place the burden of initiating corrective action on the shoulders of
the licensed services. "And as a practical matter, the FCC's proposed
rules offer no protection at all to mobile and portable stations," he
added.
Sumner also said the ARRL would continue to combat the "misconception"
that BPL systems are viable as a "last mile" broadband technology for
rural dwellers. "In low-density areas, the economics just don't work," he
said.
The NPRM is available on the FCC Web site in Microsoft Word format
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-29A1.doc or as
an Adobe PDF file
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-29A1.pdf.
Interested parties may file detailed comments on the NPRM via the main
FCC's Electronic Comment Filing System (ECFS) http://www.fcc.gov/cgb/ecfs/. The comment deadline is 45 days after the NPRM has been published in The Federal Register, and that is not expected
to happen for another week or two. The FCC also is accepting brief
comments on the NPRM via its ECFS Express page http://gullfoss2.fcc.gov/ecfs/Upload/.
NPRM Analysis and Strategies
NPRM Analysis
Jim, N3JT
(Webmaster Note: Jim Talens, N3JT is a member of PVRC, and also a lawyer with substantial experience before the FCC. I have corresponded with Jim and he consents to distribution of his analysis ... "anything that will help." Technically, his analysis is a work product for the PVRC, however they have already posted it to the RFI reflector at contesting.com so it is effectively in the public domain. It is couched in terms of a report to the officers and members of the PVRC. Jim's work is the most complete and detailed of any I have seen, and I urge everyone to study it carefully. Fred, K6DGW)
I have read the NPRM on BPL and have some comments and suggestions on how we
might respond as a club. First, though, the Comment date is not yet fixed
because it will be 45 days after the NPRM appears in the Federal Register,
which has not occurred yet. Reply Comments are due 30 days after that.
I'll try to find out when the Federal Register insertion occurs so we know
when the Comments are due. Below there are two sections, I and II. Section
I deals with the NPRM. Section II addresses my thoughts on how to file and
participate, club and individuals.
As we did with the NOI, I propose we follow the sort of approach outlined
below. I can try my hand at responding to many of these issues, but not the
technical ones. For those, we need members who can make convincing
technical arguments (and don't mind some editing along the way, just as I
will be edited). In the Reply Comment stage, we'll need a bunch of folks to
summarize the pleadings from the FCC website.
I. NPRM
It is incumbent on everyone who has an interest in the future of ham radio
to read the NPRM. It takes less than an hour, because the main document is
only 20 pages long and much of it reads quickly.
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-29A1.pdf The
Appendix B part is important because it contains the actual rule proposals.
Appendix C is critical to the technical folks because it contains the
measurement technique part, discussed above.
I think the FCC did hear the amateur community in the NOI stage of this
proceeding, but it was not entirely convinced. The NPRM tries to take a
midway path through the need to provide BPL (which at this point we must
accept as unstoppable unless Congress overrules the FCC, which is unlikely
given the relative strength of the power companies compared with the ham
community and its allies, notwithstanding one of those allies potentially
being DoD) and protecting licensed services such as ham radio. The NPRM
contains a series of technical questions and some policy questions. Here
are a few of them:
-
At para. 33 the conclusion is drawn that there are remedies that can be
used to eliminate the BPL interference. This conclusion has to be mentioned
repeatedly as justification for later procedural changes we will propose to
make sure that such remediation can and will happen.
-
At para. 35, there is a bad finding: that power line noise level
already exists, suggesting that a little more power line noise is not a big
deal. This has to be vanquished. First, the power company at least in No.
VA has been very cooperative and responds to complaints about noise sources,
which typically are from defective hardware. So the normal noise
environment is and must remain quiet. That noise from power lines is
already a significant problem for amateurs is not justification for dealing
with yet another source. Rather, it is one that is vastly more pernicious
and difficult to identify, and hence requires special procedures and
protections if licensed services are to survive (like ham radio, the
ultimate last resort for homeland security).
-
At para. 35 (toward the end), the FCC says that it would expect hams
point their antennas to minimize reception of emissions from power lines.
This has got to be corrected, and the correction must be expressed so that
it in fact shows that such directive antennas make the susceptibility even
worse. Somebody technical needs to address this in convincing detail.
-
At para. 36, the FCC acknowledges the falsity of BPL's arguments that
there is no cumulative effect from multiple Access BPL devices transmitting
at the same time in the same area. It therefore requires that measurements
of emissions be taken (see Appendices B and C) that include readings at
various distances from the equipment source. We need somebody to provide
technical comments on this proposal so that we can be sure that any emission
measurements are fair to us. There is another issue. The BPL providers
seem to claim that only discrete frequencies will be used as part of their
modulation scheme. Somebody who is more knowledgeable than I about Part 15
and the use of CDMA or other modulation techniques needs to provide
refutation. That is, if CDMA can be used, the signals are cumulative by
definition and no mitigation is possible except by filtering.
-
Para. 37 addresses non-amateur safety services. But maybe we should
claim we are public safety service providers as well (See Part 97) and in
any event the importance of such services is BEFORE interference occurs.
That is, what good is a remedy to cure interference AFTER the emergency
occurs? It is therefore critical that the power companies cease their
service upon notice of possible interference. More about this later.
-
Para. 39. What happens if a ham moves into a neighborhood where BPL
already exists? He is licensed but he gets interference. We must make it
clear that he still is licensed and has an absolute right to have the source
shut down. "Thus, operations must cease if harmful interference to licensed
services is caused." The FCC talks in terms of BPL having an incentive to
avoid interference because of its investment in plant. That cuts the other
way: they are less likely then to be willing to shut down if there is a
complaint of interference. Something has to be included in the rules to
assure that they cannot stonewall on receipt of a complaint.
-
Para. 40. BPL operators would be able to modify system performance to
mitigate or avoid harmful interference to radio services. What is
"harmful" and who makes the choice about whether to "mitigate" or "avoid"???
Avoid means to prevent; mitigate means to fix afterwards. We should
definitely require pre-operational notice to local hams or clubs so hams can
deal with the issue before subscribers become wedded to their services. And
that leads to a big, big issue: Hams may interfere with BPL. Once there
are 50 subscribers in a neighborhood, what happens when the ham insists on
shutdown from interference on HF? Do 50 subscribers just stop having
Internet access and die? No, they complain like crazy to their Congressmen
and Senators and to the FCC, and where does our ham radio public interest
value weight-in against that kind of complaint? The FCC has not addressed
this at all and it must make statements assuring hams and other licensees
that interference to BPL by hams will be acceptable. In fact, Part 15 by
its very terms assures that, but raising the issue gives us ammunition in a
future proceeding that might change the right of licensees to shut down BPL.
-
Para. 42 is the key paragraph on interference complaints. It is
critical. Questions must be addressed here: Who hits the "shut-down"
feature to deactivate interfering units? Will a ham who has a portable
receiver be able to implement that shut-down by telephone/written statement
to the power company, or must he get a power company technician out to
confirm interference (4 weeks later and with an answer of "I don't detect
any interference")? What does "have the capability to remotely exclude a
specific percentage of frequencies within this range" mean? Should we argue
for filtering of all ham radio bands? (I think so!) What about future ham
radio bands through future WRC enactments? Will power companies have to
include those in their filters? (YES!) Finally, and most critically, how
will BPL providers and manufacturers "work with amateurs"? Does that mean
ARRL should be authorized to speak for all hams to develop mitigation
requirements (and procedures, which are not mentioned)? Procedures are
important. What exactly happens if a ham thinks he has interference from
BPL? Call the power company and ask nicely for a technician to take
measurements? Should there be a 48-hour response requirement with a written
report provided to the amateur? Should hams have the right to have the BPL
service shut down if he/she detects interference and provides a technical
finding (violative of the rules) to the power company, i.e., pending a
demonstration by the power company that the power line is clean? Should the
BPL service providers be REQUIRED in all notices and contracts for BPL
service information that a complaint of interference from an amateur public
safety service provider may cause cessation of service without notice? At
the last sentence of para. 42, we should say that currently deployed systems
should come into compliance within 180 days.
-
Para. 43. Important issue: The database for BPL should include all
complaints filed and the amateur community should have representation on the
"industry-operated entity." There must be a requirement that the database
be kept up to date with all new information submitted and reflected in the
database within 5 working days of completion or complaint filing. Should
there be a central database or a regional or local one? I would suggest a
national one with web access by anybody without charge. As for proprietary
information, we can anticipate the power companies will claim that their
systems are operating in a competitive environment and they don't want to
reveal what equipment they are using, but in fact we should not let them go
there. They MUST reveal frequencies, modulation techniques, topology, etc.
Some additional issues:
-
At paras. 20 and 21, Access BPL proponents say that there have been no
complaints of interference from BPL. Is this true? Did AMRAD or has anyone
else run any tests or do we have any local evidence of interference? Even
if we do not have this information, it seems to me that this is hardly a
realistic justification for ubiquitous deployment of BPL. That's like the
old statement of a vendor that they've never gotten a complaint before
yours! First, nobody who even gets interference knows what is causing it,
let alone who is causing it or how to get in touch with the interferor. So
this issue needs some work by somebody who can perhaps contact AMRAD and
find out what's going on with them. But this is in the "summary of
comments" section and is not really an area we would comment on. Still, we
can refute the finding if it is wrong. Somebody technical needs to contact
AMRAD on this and prepare text.
-
At para. 22, BPL proponents argue that predictions of interference are
incorrect because power lines will not act like antennas. They say that
the power lines will tend to cancel each other out. They say that the
powerlines can look like point sources. We need a technical expert to
refute this with convincing technical language. All of the material in
para. 22 needs to be refuted. Somebody technical needs to contribute
language on this one.
II. Approach Proposals
-
We file our comments via electronic means on the due date. We can share
our filing with other entities (including individual members), but multiple
filings of the same text tend to make our work look like it's an effort at
stuffing the ballot box. We might share our draft with those who can
rewrite it and submit it as their own. That would include club members.
Comments?
-
We review a sampling of filed comments and prepare our Reply Comments.
-
With our initial comments, we send hardcopy via fax or letter to the
Commissioners, their staff members and all other FCC staffers who are known
to be interested in or working on this project. There are probably 75-80 of
them.
-
We prepare a cover fax sheet and send a strong letter to ALL U.S.
Congressmen and Senators, attaching our comments. Somebody has to do that.
I think email can be deleted and/or stuck in a folder too easily. The timing
of this is not as critical as the original filing, but it should be done in
the days that follow our filing. Same for our Reply Comments later.
-
I at first thought that appearing en masse in front of the FCC would be
good, particularly if we could get some press coverage. On second thought,
I think it would be impossible to express our concerns in a the 6-second
byte that TV requires, and it all might annoy the Commissioners and
undermine the efforts of ARRL and ourselves. I would not do that.
These are my initial comments. Others may take issue with all or part of
what I have offered, but we have to get started soon. There's lots of work
to be done, and it's very important.
Be Careful What You Wish For
Fred, K6DGW
Unfortunately, as is often the case in these sorts of things, the devil
is in the details, and they are often misconstrued. The unadorned facts
about BPL are:
-
It is legal now under Part 15 as an unintentional radiator. The FCC
does not need to take any action at all "to allow Access BPL," and
that's what the industry would like.
-
Several power utilities either are deploying Access BPL systems, or
say they are planning on doing so soon. PG&E is one of them.
-
The NPRM proposes: 1) to formally define Access BPL as an
unintentional radiator Carrier Current System (CCS) under 47CFR15; 2)
to make a blanket application of existing CCS emission limits to Access
BPL; 3) to extend the existing CCS emission measurement guidelines and
standards to Access BPL; 4) to require Access BPL providers to have the
capability to mitigate interference in real-time or at least semi-real
time; and 5) to require Access BPL providers to establish an as yet
undefined database of information about their deployments, complaints,
and resolutions, to be hosted by some non-government entity within the
industry (just like the existing database for the VLF and LF CCS the
power companies use for control and telemetry).
-
It does NOT allow increased emission limits for Access BPL above
what is now permitted for the VLF/LF PLC systems.
In truth, the FCC appears to have listened to the comments from the NOI
phase, at least in principle, and have undertaken rule making action to
further restrict Access BPL. Thus, a dispassionate view of the NPRM is
that it is our friend, not our enemy. We're better off with Access BPL
being specifically defined in 47CFR15, with positive language and well
defined measurement criteria suitable for HF, than to just have it
happen under the current rules.
It is likely that a number of hams will miss this crucial point, and
submit blanket arguements against the NPRM. Should the FCC listen to
them (or maybe become frustrated by them), the Commissioners could
choose to take no action at all and kill the NPRM. It's really the old
adage, "Be careful what you wish for."
We can and should address a number of issues in our comments:
-
The definition of Access BPL in the NPRM does not stipulate that it
is conducted in the HF and low VHF regions of the spectrum, as opposed
to existing PLC systems in the 15 - 490 KHz range. This is a very big
issue.
-
Emission limits suitable for VLF and LF CCS (where the "antenna" is
a very miniscule fraction of a wavelength above ground) should not be
blanketed onto an HF system (where the power conductors are 1/2
wavelength or much more above ground and act as efficient antennas)
-
Emission measurement guidelines should be appropriate for an HF
system with well elevated conductors. The current requirements specify
H-field loops, under the conductors, 1 meter off the ground. This is
great for VLF and LF systems where they are essentially transmitting
energy into an extraordinarily inefficient beverage antenna with gains
in the -50 dB or worse range. At HF, the power lines exhibit very
complex patterns with gains on many lobes of +5 to +10 dB. In general,
measurements at HF should be made at conductor elevations and above,
using E-field receive antennas, and at sufficient distance to be out of
the near-field.
-
"Real-time" mitigation needs to be defined. If my 20m CW signal
interferes with my neighbor's BPL modem, it can tell the other end to
send on a differente channel. In such case, I would hear no QRM from
the distant end (until perhaps I stopped transmitting, and the system
perceived the channel to be clear). If I do not interfere with the
distant end, my local neighbor's modem continues to use the channel, and
I hear the noise. What about people who are just listening (many hams,
SWLs, etc)? How does the system know they are being interfered with and
adaptively adjust? What about mobile radios? Blanket exclusion of all
amateur bands from BPL usage would be one approach.
-
The database needs to be defined. Providers should be required to
post their plans, schedules, equipment characteristics, geographic
areas, deployment progress, and other such data. Spectrum users should
be able to register their presence in the geographic area and be
specifically notified of progress. It should provide a means for
spectrum users to file interference complaints, track actions being
taken, and record resolutions. And, it must be readily accessible to
anyone (including individuals) at no cost. None of this is specified in
the NPRM.
The FCC actually ASKS for comments on these issues, and I believe they
will give them all consideration. In this regard, we CAN have a
positive influence. The next to last thing we want, however, is for
them to decide they've gotten it right the first time, and the absolute
last thing we want is to have them drop the action altogether.
The "It Seems To Us" and a following story posted to the ARRL's public web site makes all these points. The better we can get hams to focus their comments on reality and the positive aspects of the NPRM, the
better chance we have for keeping this all under control. Access BPL will live or die based on its economic viability. It could be great, and it could also become another example of the 8-track tape.
ARRL Info |
Analysis |
E-mails |
Comments |
Contents
Early Rollout
Dick, K6VGP
I just got this from an information service I susbscribe to called Infoworld ...... Dick K6VGP
_____________________________________________________________
Broadband over power line vendor rolls out service
Ohio, Kentucky and Indiana will have BPL service this month
By Grant Gross, IDG News Service March 02, 2004
WASHINGTON - More than a million residents of Ohio, Kentucky and Indiana will have a new broadband option this month in the first large-scale rollout of broadband over power line (BPL) service, despite concerns that the new BPL technology interferes with other radio frequency devices, including ham radios.
Current Communications Group, a BPL vendor, announced Tuesday it is teaming with Cinergy Broadband LLC, a subsidiary of Cinergy Corp., to roll out BPL service in Cinergy's coverage area by March 15, said Brian Lustig, a Current Communications spokesman. Current Communications has been conducting small-scale trials of BPL in the
Cincinnati, Ohio, and Potomac, Maryland, areas for more than a year. The large-scale rollout will be available to Cinergy's 1.5 million customers in southwestern Ohio, parts of central and southern Indiana and the Cincinnati suburbs in Kentucky. The rollout follows action by the U.S. Federal Communications Commission (FCC) in mid-February in which commissioners voted to move forward with a process to measure interference caused by BPL service. The FCC's move drew criticism from groups such as the American Radio Relay League (ARRL), which contends that BPL interferes with ham radio signals. An ARRL official wasn't immediately available to comment on Current Communications' announcement.
BPL vendors pitch the service as a third broadband choice, in addition to cable modem and DSL (Digital Subscriber Line) service. FCC commissioners have trumpeted BPL as a broadband option for customers in rural areas where cable or DSL service aren't available. Current Communications' service will allow consumers to receive broadband through their electrical outlets. Users can plug in a HomePlug power line modem into an electric socket anywhere in a house or office without professional installation or additional wiring, according to the company.
Current Communications is also planning to offer a voice over Internet Protocol service, possibly through a partnership with another company, Lustig said. Customers in Ohio, Indiana and Kentucky will be able to buy BPL service for $29.95 to $39.95 a month, depending on the connection speed. A second Current Communications joint venture with Cinergy will deploy BPL to smaller municipal and cooperatively owned power companies covering 24 million customers across the U.S. The companies have not announced a date for that second rollout.
Strategy Discussion
Kevin, N6RCE and Fred, K6DGW
Have you arrived at a plan Fred?
Well ... sort of, I'm just not sure exactly how I will approach it.
After studying the current rules, the NPRM, and some of the history
behind it (there's WAY too much history to study it all, unfortunately),
I'm stil leaning towards asking the FCC to go slowly in a phased
approach. Items in my "Points to Ponder" file (in no particular order):
-
1. We are not going to achieve an unconditional surrender of the other
guys under any circumstances whatsoever.
-
2. The interference issue has been beat to death, and the body of the
NPRM repeatedly acknowleges the potential, but they "believe it can be
mitigated."
-
3. The power industry successfully killed the attempt to get us a
"sliver" band at 136 KHz on the grounds that our signals might interfere
with existing VLF and LF carrier current control systems on the power
lines. If our signals can get in, theirs can get out.
-
4. Measurement techniques for assuring compliance at VLF/LF do not
apply well to HF. At LF, power lines are never more than a tiny
fraction of a wavelength above ground. At HF, some will be a wavelength
or more above ground.
-
5. Once deployed commercially, there is no practical way to "undeploy"
BPL should the interference prove to be severe. (This will probably be
my lead-in for a phased approach)
-
6. Need better definition of the "central database" run by the industry
that's called out in the NPRM. Who owns it? How is it accessed? Can I,
as an individual, get to it, follow the progress of BPL deployments in
my area, file claims of interference, and follow their resolution?
Fred K6DGW
Auburn CM98
Kevin Rowett wrote:
There are a couple of systems that are nominally BPL, but, aren't carrier current based. None are ready for production yet though.
Of course, CCS has always been a VLF and LF thing. BPL is an HF thing, and that's the set of issues we need to attack. Unfortunately, that message isn't being advertised to the ham community well. I've written three drafts of comments, and I still can't come up with something that will cause the commission to stop and re-consider. I've about settled on just pointing out the facts as I see them, sending those in, and then getting every one I know to send in comments too.
As of Monday evening, only 6 comments had been filed - several of those won't do much to influence the commission. I know most people won't file comments till close to the deadline.
BPL has become a "popular" item among the press and web mazagines. Most people are in favor of BPL. The commission is in a bit of a hard spot - generally, the american public wants it - however, the commission must take into consideration the technical issues that the general public can't understand.
Have you arrived at a plan Fred?
N6RCE
Draft Letter to Senator Boxer
Gary, KE6QR
Dear Senator Boxer,
I am a licensed Amateur Radio operator and I have a complaint concerning the FCC (Federal Communications Commission). This concerns the Commissions handling of Notice of Proposed Rulemaking (NPRM) as expressed in ET Docket 03-104 and ET Docket 04-37 for the implementation of BPL (Broadband Powerline) over our nations electrical powerlines.
This concern is made over the documented interference caused by Access BPL to the HF spectrum. It is clear that evidence submitted during the Notice of Inquiry period cannot have been thoroughly or comprehensively reviewed or the Commission would have recognized that Access BPL interference to the HF spectrum has been well documented.
The largest objection to the rollout of Access BPL is based upon the interference that it causes to licensed users of the radio spectrum. While the Commission acknowledges this objection, the decision has been made to proceed even though initial studies have
concluded that BPL interference is likely. Studies that will provide additional clarity to the full interference potential of Access BPL by National Information and Telacomunications Administraion (NITA) and the American Radio Relay League are still in process, even in the face of these, the Commission has dismissed the prudent opportunity to analyze their findings prior to issuing the NPRM.
Allowing BPL to proceed before these studies have been completed puts both licensed users of HF spectrum and Access BPL users at risk. While the Commission recognizes the risk to licensed radio users in the HF spectrum, even with many countries including
Japan prohibiting Access BPl due to interference, they continue to push the BPL technology.
I feel that the FCC is having a "Conflict of Interests". Those that need to make sound
technical judgement are not. The Commissions job is to protect licensed radio users, not cause harm to them with harmful interference by promoting a technology that is not
compatible with licensed radio services. The interference issue is also raised by NITA, FEMA, World Broadcasters and others.
The Amateur Radio service provides our nation with skilled, volunteer communicators who provide emergency communications during times of emergencies. I feel that if Access BPL is allowed to operate in our country not only will the Amateur Radio service be in jeopardy, Homeland Security will be threatened as well. I respectfully urge you to ask the Commission to delay any implementation of Access BPL until all interference issues have been resolved.
Respectfully
Gary W Gross KE6QR
{address deleted}
Skywave BPL Interference
Kelly, N6KJ
This article mentions an FCC commissioner's description of how a typical interference claim would be handled:
1) The complainant looks for a nearby BPL system in a database
2) The complainant contacts the BPL system administrator
3) The BPL system administrator adjusts the network behavior to mitigate the interference.
I won't even jump on my soapbox to talk about how much a pain it will be to
get interference claims handled. I know many of you already have experience
with PG&E in this area. I would have a lot more respect for the FCC's
plan if I knew that existing noise problems on power lines were dealt with
in a timely manner.
My bigger question is: what if the BPL interference isn't caused by
a local BPL system (ie. what if the BPL interference is caused by
skywave propagation)? How the heck is someone supposed to figure THAT out?
I would have more respect for the FCC's plan if I saw even a small amount
of concern on their part for potential long distance propagation of BPL
noise AND for the overall raising of the HF noise floor. All I see is a
plan to band-aid individual complaints. Heck, I'm sure I have an
increased noise floor in my area due to all of the crappy switching
power supplies, neon lights, light dimmers, etc. but there is no way
I could possibly find all the sources let alone get them fixed. I suppose
they don't consider this "harmful interference".
Info From Antennex Reflector
(Email addresses have been deleted or placed into graphics to protect them from spam harvesters)
From: antennex.com
Sent: Monday, March 22, 2004 7:25 AM
To: newslist-(at)-antennex.com
Subject: [antenneX] BPL/PLC Protest Document
* * * Public Service Announcement * * *
Folks:
Tom Cox, KT9OM has initiated and authored a very fine document in protest to the movement toward BPL/PLC in the USA. It will be submitted to the FCC for their consideration as part of their final determination for widespread approval in the USA.
Thanks also go out to the many members on the antenna-discussion mail list that made very useful suggestions for Tom to incorporate in his final document. We have also heard about some experiences with this issue from those already exposed to the use of power lines for broadband propagation in Europe, which has helped in this effort.
We now have a 3rd revision of Tom's document just about ready to submit to the FCC. I have now made this document available to all interested parties who may like to review the document and submit more suggestions of importance to consider.
If you have an opinion of substance that hasn't already been considered, please let us know right away. It's now or never since the BPL/PLC has gathered strong momentum toward implementation. Our thanks to Tom's very fine effort on this important issue.
This 3rd revision can be accessed at:
http://download.antennex.com/docs/bplcomments3.pdf
For feedback, you may contact me at:
...and Tom Cox at:
It's probably more expedient to send your responses to both of us. We
need to submit this document as soon as possible as time is of the
essence.
Thanks for any other suggestions and participation!
Jack L. Stone
antenneX Online Magazine
www.antennex.com
FCC-ARINC Dispute in Half Moon Bay, CA
I want to call everyone's attention to a comment (actually a scanned image of a letter -- takes awhile to download) filed by the FCC. It is dated 03/23/2004, and can be found at http://svartifoss2.fcc.gov/prod/ecfs/retreive.cgi?native_or_pdf=pdf&id_document=6516083909.
In it, the FCC staff take strong issue with a comment made by ARINC regarding interference to their 3.013 MHz Air-Ground channel at Half Moon Bay, CA. ARINC (the company that provides HF air-ground communications worldwide) alleged that they were receiving devastating QRM on this channel, and that the FCC had not responded. The referenced FCC letter obviously takes issue with this allegation.
The message to all of us is, "Be wary when quoting or referencing others' comments from the NOI and NPRM phases in your own comments. " Another example is just above the FCC letter in the ECFS page: a letter from Homeland Security (FEMA), significantly softening their original concerns about BPL. Ham discussions, QST, and others have referenced that original FEMA position as being supportive to our positions. Apparently, they "rethought" their concerns.
Fred, K6DGW
Auburn CA CM98
Short Note on Filing Reply Comments
Fred, K6DGW
The public comment/reply comment period for the FCC (as for all Federal agencies) is governed by some fairly strict rules, and to have your comments considered, it is important to comply with them. The "Comment Period" has passed, and we are now in the Reply Comments period. The fundamental rule here is that "You can only comment on already filed comments." That is, you can't submit new information. Some guidelines:
1. For each of your reply comments, clearly identify the original comment(s) you are addressing, citing the commenter's name and a filing date. You can do it in a footnote, or within your text.
2. If the original comment covers more than one issue, identify the specific issue you are addressing, by paragraph number or title, or by quoting it directly.
3. If you take issue with the comment (e.g. point out that it is untrue, or inconsistent, or whatever), be sure to cite your source. For example, if the comment states that BPL devices behave as point sources, you might cite the relevant parts of the NTIA Phase I study where they show that to be untrue.
4. You can consolidate your reply comments for all commenters into one filing if you want, just pay particular attention to #1 above. However, you are free to file as many reply comments as you wish, and if they are extensive, you might want to consider filing against each commenter separately.
5. The FCC will organize summaries of all comments and replies to them for the Commissioners. The better you tie a specific comment to the supporting information that refutes it, the easier you make the FCC staffs' task.
The total number of comments files is "rather extensive," and attempting to read and study them all is probably out of the question for most of us. I'd suggest you restrict your interest to those commenters who are likely to take a pro-BPL position, and to the ARRL comments and NTIA Phase I report.
UPLC Press Release and K6DGW Reply
Fred, K6DGW
In case you haven't seen it, the UPLC (trade organization representing and promoting the industry) has issued a Press Release that is really quite unique. You can find it at www.uplc.utc.org. Go down to the bottom of the opening page, and it's the top item in "Press Releases."
Because I was really offended by it, and because I am retired and have a little time, and ignoring the fact that I know this will have no effect, I drafted an e-mail reply to them, which follows. My (short) reply follows:
--------
Dear UPLC:
I celebrated my 64th birthday this month, 51 of those 64 years as a
licensed amateur radio operator (K6DGW). I hold a BS in Mathematics
from California State Polytechnic University in Mathematics and an MS in
Computer Science and Engineering from California State University
Sacramento. I served ten years as a communications officer in the US
Air Force, four of them as a combat communications officer in Laos, and
South and North Vietnam, (where, incidentally, it was "armchair
amateurs" with vacuum tube equipment in the US who kept me and my
comrades in touch with our families). In civilian employment, I worked as
an Engineer, Senior Project Engineer, Project Manager, and Chief
Engineer on way more successful major RF-based communications projects
than I can remember.
One would think that by now, and with all that experience, I would be
fairly well hardened against the typical hyperbole, unfounded
assertions, and outright untruths that single-issue politicized trade
organizations such as UPLC emit to the press from time to time. I must
admit, your invective and off-hand dismissal of the very extensive and
well documented NTIA Phase 1 study is appalling, however, coming from an
organization that purports to represent a technology industry. Shame on
you! I really thought you were adults.
Your 22 June 2004 press release with the same title as the subject of
this message renews my faith and conviction that there is no limit to
the depths you and your colleagues will sink to in an effort to achieve
your ill-founded goals at the expense of others. It is of course an
election year, and hyperbole, unfounded assertions, and outright
untruths are pretty much ubiquitous around us. However you will surely
get the Achievement Award in that area.
I have performed analysis for my own station, in a semi-rural area
without access to either DSL or cable broadband due to distance. It
would be a prime candidate for BPL if one believes Mr. Michael Powell
and the President. The coupling factor between the 12KV distribution
lines that traverse my property in several directions and my antennas is
in the range of -37 - -39 dB on all amateur frequencies below 30 MHz,
except for the 1.8 - 2.0 MHz amateur allocation. There, it ranges
between -12 dB and -15 dB, primarily because at that frequency, the
power lines and my antennas are embedded in each other's near field. My
receivers have a practical sensitivity of -140 to -150 dBm for a 10dB
(S+N)/N, and I and other amateurs consistently receive signals at or
well below that power.
I am authorized by the terms of my license and the FCC rules and
regulations at 47CFR97 to transmit with 1 kilowatt of input power using
morse telegraphy and constant envelope emissions (about 650 watts
output), and with an equivalent peak envelope power using voice.
If you're intellectually capable of it (questionable, given your press
release), why don't YOU do the math. Or, if that is beyond you
(likely), let me do the math for you -- 10^-9 watts (that would be a
nanowatt, probably far below what you are likely to need) from a BPL
provider's injection devices, 89 meters from the edge of my property
(that's where a pole is), will produce a signal of about -99 dBm at my
receiver terminals. You can rest assured that I will hear it, if/when
it comes to my neighborhood, and, at 40 dB above a fairly strong desired
signal, it will clearly be harmful. Since BPL is a Part 15 device, the
provider must cease creating harmful interference to licensed services.
Rest assured, I will file the complaints, and eventually, the provider
will remove the interference. It puts an unfair burden on me, but then,
I'm retired and I have the time.
And you can rest more assured that your subscribers will hear me as
well. Again doing the math for you so it is clear, 650 watts is 650,000
milliwatts, or +58 dBm. With a coupling factor of -39 dBm, your
members' BPL receiving device is going to see about +19 dBm or 80
milliwatts of my emissions at it's input terminals. The Part 15 device
and its operator are responsible to live with that, of course. Good
luck.
And, in the interest of the truth ... while you are resting assured
about all of the above, you might use your spare time to correct the
"Manassas Virginia" story on your home web page. They didn't "turn up
BPL in the city," it was a test for a few residents in a very small
area, and it was NOT available to "all residents and businesses." There
were no licensed amateurs (or other licensed users of the HF spectrum)
located in the test area. And, I write this in the past tense because
Prospect Street Broadband abandoned the project earlier this year, and
at last word, the City of Manassas had acquired some or all of the
physical plant and was searching for a new franchisee. Oops, I forgot
... truth is not one of your goals, is it. My apologies.
The Commission will most likely adopt and order the changes to Part 15
contained in the NPRM and Docket 04-37 inasmuch as they all have already
said they would long before the public comment and reply comment periods
on the matter closed, and our current elected government shows little
interest in scientific fact. In that, you will claim success. In the
end, however, when the real laws of physics and electromagnetic
radiation and not your fabrications and assertions prevail, and the
economics of your ill-advised adventure that has failed in other
developed countries in the world turn into real lost money, you and your
members will lose. I, for one, certainly hope it's a bundle.
Sincerely,
Fred C. Jensen
Amateur Radio Service Licensee K6DGW
670 Old Airport Road
Auburn CA 95603
ARRL Info |
E-mails |
Comments |
Contents
Home
Auburn CA
Pick Your Nerd
General Info
ARRL Info