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![Previous (earlier) Story](/images/sty-down.gif "ARRL Releases Updated "Logbook of the World" Beta Software"){kind=small} Previous: ARRL Releases Updated "Logbook of the World" Beta Software |  Next: ARRL In Action: What Have We Been Up To Lately? |
By David Sumner, K1ZZ
ARRL Chief Executive Officer
June 1, 2003
Editor's note: Typically, only ARRL members get to read the "It Seems to Us ..." editorials that run each month in QST. We're posting this editorial that appears in the June 2003 issue of QST in the hope that both ARRL members and nonmembers might appreciate it and find it informative.
No one should doubt that the Federal Communications Commission (FCC) has a difficult job. Its roots lie in the establishment of the Federal Radio Commission (FRC) in 1927. The force behind the creation of the FRC was chaotic interference that threatened to destroy the fledgling broadcasting industry by driving listeners away. Too many stations were being put on the air with inadequate coordination. In other words, the marketplace alone was inadequate to control individual broadcasters' behavior; regulations were needed to protect the industry from itself.
One of the FCC's obligations under the Communications Act is to "generally encourage the larger and more effective use of radio in the public interest." Like any resource, the radio spectrum is finite. One way to ensure that the largest and most effective use of the spectrum can be made is to prohibit unnecessary emissions. Thus, minimizing interference remains a fundamental regulatory mission of the FCC.
On the other hand, U.S. policy is to encourage the provision of new technologies and services to the public. FCC Chairman Michael Powell's interpretation of this policy is that his Commission should be a "cheerleader" for new technologies. On April 23 during an Open Meeting he used that very word to describe the FCC's role with regard to the deployment of a technology that gives us grave concern: broadband power line communications, generally referred to as PLC but now dubbed BPL, for Broadband over Power Line, by the FCC.
The reason for our concern is simple. "Access BPL" involves the introduction of RF energy in the range from 2 to 80 MHz onto so-called "medium voltage" power lines that run along nearly every road and street and into every neighborhood. They are the lines that connect the transformer feeding your home to the nearest substation. According to industry sources, data rates of up to 20 MB/s are possible for distances of up to 2,000 feet, and of up to 3 MB/s for distances of up to 4,000 feet. Because the power lines are already in place in existing rights-of-way, this makes the technology potentially attractive for delivering broadband services such as Internet access. "In-House BPL" involves much the same thing for LANs using the existing AC wiring in the walls of homes and offices.
BPL does not require that this RF energy be radiated. However, as most of you reading this page no doubt already have realized to your horror, it will radiate for the simple reason that there's nothing to stop it. Power lines are unshielded. They are designed to be transmission lines at 60 Hz, not at HF or VHF. For a radio service such as ours that relies for its very existence on the ability to detect and decipher weak signals, including from our automobiles as we drive under these very power lines, BPL could be an intolerable polluter of the radio spectrum. That this would be merely an unintended consequence of BPL deployment -- collateral damage, if you will -- does not ameliorate the situation.
What the FCC did at its April 23 meeting was to adopt a Notice of Inquiry (NOI) regarding "Carrier Current Systems, including Broadband over Power Line Systems" (ET Docket No. 03-104). In the words of the NOI:
Through this inquiry, we seek information and technical data so that we may evaluate the current state of BPL technology and determine whether changes to Part 15 of the Commission's rules are necessary to facilitate the deployment of this technology. While BPL may be deployed under our existing Part15 rules, the rules do not specifically provide measurement procedures that apply to systems using the power line as a transmission medium. We therefore seek comment on what changes, if any, we should make to our Part 15 rules to promote and encourage the new BPL technology and to our measurement procedures for all types of carrier current systems. We further encourage present deployment of BPL that complies with our existing rules, noting that if, or when, our rules are modified, those rules will address prospective compliance.
The Commissioners were rather effusive in their praise of BPL technology as an additional competitor, along with cable and DSL, in the delivery of broadband services to the public. Their favorable impressions were based largely on a single carefully orchestrated "dog and pony show" to which they had been invited in suburban Maryland. (Needless to say, we weren't invited. We'd have brought along an HF receiver for them to listen to.) The NOI does at least raise interference as an issue [emphasis added]:
In both Access and In-House high-speed BPL technologies, multiple carriers spread signals over a broad range of frequencies that are used by other services that must be protected from interference. In the spectrum below 30 MHz, incumbent authorized operations include fixed, land mobile, aeronautical mobile, maritime mobile, radiolocation, broadcast radio, amateur radio terrestrial and satellite, and radioastronomy. In the spectrum from 30 to 300 MHz, incumbent authorized operations include fixed land mobile, aeronautical mobile, maritime mobile and mobile satellite, radioastronomy, amateur radio terrestrial and satellite, broadcast TV and radio. This spectrum is also used for public safety and law enforcement, and Federal government aeronautical radionavigation, radionavigation satellite and radiolocation. Each of these authorized services in the spectrum must be protected from harmful interference.
Rest assured that the ARRL will do everything in its power to hold the FCC to that promise.
The deadline for comments was not set at press time but probably will be in the latter half of June. We will be posting as much information as possible, as quickly as possible, on the ARRL Web site for use by members and others interested in filing their own comments.
We have a long, hard fight ahead of us.
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