 |
 |
|
|
|
|
|
|
||||||||||||||||||
|
|
|||||||||||||||||||
|
|
|||||||||||||||||||
|
|||||
|
|
July 8, 2003 -- "BPL is a Pandora's Box of Unprecedented Proportions," ARRL Tells FCC
Citing the potential for interference to and from Amateur Radio, the ARRL has called on the FCC to "take no steps" to permit Broadband over Power Line (BPL)--a form of power line carrier (PLC) technology. The League has filed a 120-page response--including studies--in response to the FCC's BPL Notice of Inquiry (NOI) in ET Docket 03-104, published May 23. The NOI asking how the FCC should regulate the delivery of broadband services to homes and businesses using electrical wiring to conduct high-speed digital signals attracted some 1900 comments--many from the amateur community--by the July 7 comment deadline.
[Full Story]
Additional Resources:
The FCC has agreed with a request made in early 2001 by SAVI Technology Inc (and fiercely opposed by ARRL) and has proposed changes to its Part 15 rules governing unlicensed devices that would allow operation of advanced RF identification devices between 425 and 435 MHz.
The ARRL contends that the Part 15 RFID proposal--included as part of a larger Notice of Proposed Rule Making and Order--is contrary to the philosophy of Part 15 rules and that the RFID devices SAVI proposes more properly belong on frequencies also authorized for use by devices regulated by FCC's Part 18 Industrial, Scientific and Medical (ISM) rules. The League maintains that deploying such RFID devices on 70 cm could result in significant interference to amateur operations and plans to file a strong opposition to the FCC's NPRM&O.
The problem is that since 1938, the 40-meter allocations in the three ITU radio regions are different. Region 2 has 300 kHz from 7.0-7.3 MHz, while Regions 1 and 3 have 100 kHz from 7.0-7.1 MHz (7.1-7.3 MHz in these Regions are currently allocated to the broadcasting service). WRC-2003 agenda item 1.23 is an opportunity to realign the amateur and broadcasting bands around 7 MHz. The amateur service seeks the return to an exclusive, worldwide allocation of no less than 300 kHz in the vicinity of 7 MHz. For further information see http://www.iaru.org/7-MHz-Spectrum.pdf.
Studies of WRC-03 matters relating to the amateur services are conducted in ITU-R Working Party 8A. WP 8A is developing text for the Conference Preparatory Meeting, which is charged with preparing the technical basis for WRC-03--the so-called CPM Report. ITU-R WP 6E (broadcasting emissions) and WP 9C (HF fixed service) are interested working parties, and are exchanging information with WP 8A.
There is a potential threat that the possible expansion of spectrum below 10 MHz by broadcasters may complicate consideration of the amateur band at 7 MHz. See the item related to HF broadcasting, below.
WRC-03 agenda item 1.36 calls for the WRC "to examine the adequacy of the frequency allocations for HF broadcasting from about 4 MHz to 10 MHz, taking into account the seasonal planning procedures adopted by WRC-97."
HF broadcasting now has regional allocations of 3950-4000 kHz in Region 1 and 3900-4000 kHz in Region 3, and footnotes affording very limited use of 3950-4000 kHz in Greenland. We will resist any expansion of broadcasting that would further reduce the usefulness of the 3500-4000 kHz band to amateurs in Region 2.
Another agenda item, 1.2, provides for a review and taking any required action concerning possibly dropping the idea of HF broadcasters changing from double-sideband AM to single-sideband modulation and migrating, instead, to digital modulation, known as Digital Radio Mondial.
It is too early to tell, but there is the possibility that HF broadcasters might obtain additional spectrum during the transition from analog AM to digital broadcasting.
Both of these items could add confusion to the already difficult WRC-03 agenda item 1.23, that of realignment of the bands around 7 MHz.
Operation of Synthetic
Aperture Radars (SARs) at frequencies around 400 - 500 MHz would permit
collection of data through the dense upper canopy of tropical rain forests.
WRC-03 agenda item 1.38 asks the Conference to consider provision of up to 6 MHz of frequency spectrum to the Earth exploration-satellite service (active) in the frequency band 420-470 MHz.
ITU-R Working Party 7C (responsible for active Earth-exploration satellites) continues to study compatibility between SARs and existing users of the band 420 - 470 MHz, with the band 430 - 440 MHz preferred by the SAR proponents. Ken Pulfer, VE3PU (IARU) and Walt Ireland, WB7CSL (ARRL in the US Delegation) are regular participants in the work of WP 7C and the new WP 7E established to consider sharing and WRC preparation. There has also been an exchange of information with WP 8A, the amateur service's "home" in ITU-R.
Technical studies by the League and IARU are continuing to assess the potential interference from SARs to amateur stations, including amateur satellites in the band 435 - 438 MHz.
Prior to the end of 2002, the Federal Communications Commission (FCC) is expected to issue a Report and Order authorizing short-range devices using ultra-wideband UWB) technology. Potential applications could include ground penetrating radar (GPR), through-the-wall radar and lesser-well-defined communications systems. GPR systems typically operate below 1 GHz and are considered somewhat benign because the energy is pointed downward. Even wall radars may not be a problem because their duty cycle could be low. Use by construction firms and rescue squads could be typical applications. Communications uses could be a problem, depending on frequency spread, duty cycle and how widespread their eventual deployment. The airline industry is especially concerned about the possibility of UWB devices, such as electronic games, being inadvertently on and causing a safety-of-life hazard.
Depending on what the FCC decides, UWB devices could operate under Part 15 rules on a center frequency in the UHF band, possibly 1.5 GHz and spread their energy over a band at least 25% of that center frequency. UWB devices produce extremely short pulses and are expected to use very low power.
ARRL is a member of a US industry coalition lobbying the FCC, other federal agencies and Congress with a view toward having the Commission release a Further Notice of Proposed Rule Making with proposed technical characteristics and service rules for UWB. Heretofore, the FCC has declined to do so.
The International Telecommunication Union (ITU) has not studied UWB or its effects on radio services. In November, ITU-R Study Group 1 adopted two Questions concerning technical and administrative aspects of UWB. Results of these studies are expected by 2003.
Fixed wireless access (FWA)
is the term used for telephones at fixed locations connecting to the public
switched telephone network by radio instead of the usual twisted pairs. You may
also see it called wireless access systems. (WAS) or wireless local loop
(WLL). FWA proponents predict that in a decade there will be more wireless than
wired telephones.
Radio local area networks (RLANs) are a related technology. The concept is that people and their computers need to move around inside buildings and within a campus.
The problem for us is that FWA and RLANs have a voracious appetite for frequencies and some of our bands are in their sights.
FWA and RLAN proponents have been pursuing the 3400-3700 MHz band through the ITU, specifically in Joint Rapporteurs' Group of Working Parties 8A and 9B (known as JRG 8A-9B). In addition, they have been studying numerous bands from about 25 MHz upward to find spectrum for their use. Bands of most interest to them at present are:
440 - 450 MHz (It is unlikely to affect the USA, as the domestic allocation of this band is RADIOLOCATION (primary) and Amateur (secondary). However, FWA could be used in countries with domestic fixed service allocations, such as Mexico and Peru.)
3400 - 3800 MHz (The band has grown to 3800 MHz. Of this band, only 3400-3500 MHz is an amateur secondary allocation. We also have a secondary allocation at 3300-3400 MHz, which has not been targeted by FWA advocates. The band 3300-3400 MHz is allocated to RADIOLOCATION on a primary basis and the amateur service on a secondary basis.)
5650-5725 MHz is a band in which the amateur service has a secondary allocation (the RADIOLOCATION service is primary. WRC-03 agenda item 1.5 asks the Conference to consider spectrum requirements for new and additional allocations to the mobile, fixed, Earth exploration-satellite and space research services, and to review the status of the radiolocation service in the frequency range 5150-5725 MHz.). RLAN proponents would like to see the band 5650-5725 MHz, among others, allocated to the mobile service for RLAN applications.
10.15 - 10.3 GHz (Channels 1.75 MHz wide are proposed for FWA.)
ARRL and IARU are monitoring ITU and regional meetings studying spectrum possibilities for FWA and RLAN applications.
On October 22, 1999, the FCC released a Report and Order under ET Docket 98-95 allocating 75 MHz of spectrum at 5850 - 5925 MHz to the mobile service for use by Dedicated Short Range Communications (DSRC) systems operating in the Intelligent Transportation System (ITS) radio service. In their R&O, the FCC stated, "The record in this proceeding overwhelmingly supports the allocation of spectrum for DSRC-based ITS applications to increase traveler safety, reduce fuel consumption and pollution, and continue to advance the nation's economy." The FCC acted under the Transportation Equity Act for the 21st Century signed by the President calling for an allocation to be made no later than January 1, 2000.
The League argued that this allocation together with the U-NII allocation in the 5725 - 5825 MHz band could impact the amateur services. The FCC replied that "...amateurs historically have been able to design and modify their systems to avoid or minimize interference..."
This is a shared band including worldwide allocations for the fixed service, fixed-satellite service and mobile services, and in Region 2 a secondary allocation for the amateur and radiolocation services. Amateurs need to find ways of sharing this spectrum with these new sharing partners.
The low-Earth-orbit satellites operating at frequencies below 1 GHz are known as Little LEOs. There are fewer Little LEOs now because of insufficient markets for this type of service in these times of many other options. Nevertheless, proponents continue seeking additional service link spectrum in bands below 1 GHz and feeder link spectrum around 1.4 GHz.
We remain vigilant about the
potential threat to amateur bands, and will remain so until the alleged need
for additional Little LEO spectrum is resolved.
