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 Previous: W6RO Celebrates 25 Years of Operation from the Queen Mary |  Next: FCC Amateur Radio Enforcement Letters for the Period Ending May 1, 2004 |
NEWINGTON, CT, May 5, 2004--Calling broadband over power line (BPL) deployment on HF "a mistake, purely and simply," the ARRL asked the FCC to put its BPL proceeding on hold to allow more thorough research of its interference potential to licensed radio services. In comments filed May 3 in response to the FCC's February 23 Notice of Proposed Rule Making (NPRM) in ET Docket 04-37, the League also called on the FCC to apply "considerably more conservative radiated emission limits" to BPL than those applying to "normal" Part 15 devices. Five technical exhibits, including an ARRL-commissioned independent study at BPL trial areas and additional research accompanied the League's comments.
"The Commission cannot be in such a hurry to deploy BPL as a potentially competitive broadband delivery mechanism that it must sweep under the rug the mounting evidence that BPL is a significant source of interference to licensed radio services and is not in the public interest," the ARRL declared. The League was among more than 1000 individuals and entities commenting in the proceeding by the May 3 deadline. Reply comments are due Tuesday, June 1. On the eve of the comment deadline, the FCC denied several requests--including one from the ARRL--to extend the comment period.
The League reiterated its assertion that the BPL proceeding "constitutes a blind rush to judgment" for no apparent reason other than to foster broadband competition. And it took the FCC to task for its willingness to balance BPL's presumed benefits against the potential of harmful interference. "The principal obligation of the Commission in permitting unlicensed devices or systems is to establish a radiated emission level that is sufficiently low that by their operation they will predictably not interfere with licensed radio services," the ARRL emphasized.
"Indeed, in this proceeding, all indications are that the Commission simply does not want to hear the bad news, only the good, about BPL," the League said. "The Chairman has self-described himself as a 'cheerleader' for the technology." The League said it wanted the opportunity to review the lengthy National Telecommunications and Information Administration (NTIA) Part 1 BPL study released April 27 (see "NTIA Study Documents Radio Interference from BPL.").
The ARRL told the FCC that applying existing radiated emission limits to so-called "access BPL" systems is inappropriate. "Those levels are far too high and were designed to address the interference of point source radiators," the League said. "It is obvious that access BPL systems are distributive, line-source radiators" and the FCC should apply a limit "sufficiently low as to prevent interference to mobile stations" that might operate in a BPL-served neighborhood. The ARRL suggested that 0 dBuV/m at the antenna measured at 10 meters (approximately 33 feet) from the power line would be an "acceptable" radiated emission level.
The League proposed amending Part 15 rules (§15.109) to require BPL systems to incorporate adaptive interference resolution techniques adequate to cause them to cease operation within an hour following a report of harmful interference to an FCC licensee's station. The BPL system then couldn't resume operation within one kilometer (approximately 0.62 mile) of the complainant's station "unless and until the harmful interference is resolved." The ARRL also would require BPL systems to supply detailed information on their systems to a public Web-based database.
The League says the FCC's NPRM offers no support for its conclusion that interference to licensed services would be minimal, and it noted that amateur licensees have filed more than two dozen BPL interference complaints with the FCC.
"Some of these interference problems have persisted, notwithstanding the good faith efforts of some BPL service providers to resolve the problems," the ARRL said. In other cases, the complaints are simply ignored. None has been adjudicated by the Commission, as far as the ARRL can tell."
Instead, the League said, amateurs' BPL complaints "remain under wraps" in the Office of Engineering and Technology instead of being handled by the FCC's Enforcement Bureau, which typically deals with power line noise complaints from radio amateurs.
"Mere mitigation" of interference is not sufficient, the ARRL said. "It is the absolute obligation of the operator of a Part 15 device or system to prevent interference," the League's comment said, pointing out that the FCC's NPRM does not require interference resolution. "It only requires some unspecified 'mitigation,' and the determination of what level of mitigation is sufficient is apparently left to the subjective evaluation of the BPL provider."
"The interference to fixed amateur stations located in residences in normal geographic proximity to overhead power lines will be devastating and will preclude Amateur Radio communications," the League said, calling the mitigation techniques the FCC has proposed "too little, too late to avoid widespread interference."
Referring to its main BPL study, the League said measurements at one site within a BPL test system in Emmaus, Pennsylvania, "exceeded FCC Part 15 limits by up to 20 dB or more. At another test site in Whitehall, Pennsylvania, where another technology has been deployed, the study concluded that the BPL signals, while apparently within Part 15 limits, "would have interfered seriously with reception of Amateur Radio signals."
The ARRL contends that the FCC's "overly aggressive timetable" to proceed with BPL systems will effectively preclude the development of cooperative interference avoidance and resolution mechanisms.
"This proceeding should be placed on hold for a year in order to work out appropriate interference avoidance and resolution standards," the League concluded.
Other entities filing comments in the proceeding included AMSAT-NA, the North American Shortwave Association, and the Association of Public-Safety Communications Officials-International Inc (APCO) and the National Public Safety Telecommunications Council (NPSTC), which filed joint comments.
Viewing Comments on the BPL NPRM
Interested parties may view all comments filed on the BPL NPRM via the FCC Electronic Comment Filing System (ECFS). Under "ECFS Main Links," click on "Search for filed comments" and enter "04-37" (including the hyphen but without the quotation marks) in the "Proceeding" field. (Users also may enter other parameters in the form to view, for example, comments filed by a particular individual or entity.)
Once the
ECFS has downloaded the initial set of comments (typically the 100 most
recently filed), users can scroll to the bottom of the screen and click "All"
to have the system show all comments posted on this proceeding.
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