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 Previous: FCC Warns Additional Trucking Firms About 10-Meter Unlicensed Operation |  Next: Surfin': Parties and PCBs |
 The FCC will consider a draft R&O on BPL at its October 14 meeting. (L-R) Commissioners Kevin Martin, Kathleen Abernathy, Chairman Michael Powell, Michael Copps and Jonathan Adelstein. [FCC photo] |
NEWINGTON, CT, Sep 24, 2004--The FCC Office of Engineering and Technology (OET) will present a broadband over power line (BPL) Report and Order to the full Commission when it meets October 14, the ARRL has learned. More than 6100 comments have been filed on the topic since the FCC released its initial Notice of Inquiry in the proceeding, ET Docket 03-104, in April 2003 and a subsequent Notice of Proposed Rule Making (NPRM), ET Docket 04-37, in February of this year. The ARRL so far on this round has taken its concerns regarding Amateur Radio and BPL to three of the Commission's five members. In a meeting this week with FCC Commissioner Jonathan S. Adelstein, an ARRL delegation again asserted that the FCC is pushing the proceeding to a predetermined conclusion with little regard for technical issues.
"Because the FCC has been unwilling to release for public review the results of its own tests and observations of BPL systems, the ARRL has no confidence that the draft Report and Order will be based on sound engineering and believes the rush to adoption is unwarranted and premature," ARRL Chief Executive Officer David Sumner, K1ZZ, said in a follow-up letter to Adelstein. The letter reiterated the League's key points that, it said, "represent the minimum protection" that should be incorporated into the BPL Report and Order prior to Commission adoption.
"Without adequate safeguards, the deployment of BPL systems will result in the pollution and degradation of the unique natural resource of the high-frequency radio spectrum," Sumner said.
The League argued that a reduction in the radiated emission limit for BPL systems be included in the R&O. The ARRL wants the limit set 30 dB below current Part 15 requirements, which, it says, were established with narrowband point-source radiators in mind. "The record in this proceeding clearly establishes that BPL is not a point-source radiator," the ARRL's letter asserted.
The ARRL pointed out that the National Telecommunications and Information Administration (NTIA) has concluded that at the current Part 15 limit, interference is "likely" to receivers in land vehicles 75 meters from BPL-connected power lines and to fixed stations 460 meters from such power lines.
"Given the number of amateur stations and the fact that they almost invariably are located near power lines, the areas of potential interference at the existing Part 15 limit are clearly too large to permit case-by-case resolution of interference issues," Sumner said. "Based on experience with the very limited test deployments of BPL systems to date, notably in Cedar Rapids, Iowa, Southern Wake County, North Carolina, and Cottonwood, Arizona," the ARRL told Adelstein, "widespread BPL deployment at the existing Part 15 radiated emission limit will result in an unmanageable incidence of interference."
The only way to reduce these areas of potential interference is to reduce the radiated emission limit, the ARRL maintained. Mandatory "notching" of the amateur bands by 30 dB would reduce the probability of interference to amateur stations sufficiently that the remaining interference cases might be resolved on a case-by-case basis. "However," the League added, "such notching would not solve the problem for other radio services."
The ARRL contingent, which included Sumner, ARRL General Counsel Chris Imlay, W3KD, and ARRL Chief Technology Officer Paul Rinaldo, W4RI, decried the FCC's lack of response to issues Sumner raised two months ago regarding a North Carolina Amateur Radio interference complaint. The ARRL representatives carried copies of correspondence questioning a July OET report that essentially gave the Progress Energy Corp BPL field trial a clean bill of health despite continued interference on amateur frequencies.
The League delegation suggested to Adelstein that the OET has swept the North Carolina BPL interference case under the rug and has attempted to discount interference issues in general while overstating the FCC's ability to address them.
Additional BPL-Related Concerns Raised
The ARRL also has asked Commission members to consider including the NTIA's recommendations to standardize measurement procedures and to require that Access BPL systems be certificated, not merely verified. The League has further stressed the need for independent confirmation of rules compliance before a BPL system is placed in operation.
Other points the ARRL has emphasized in its meetings with Commission members include the need for advance public notification of BPL system locations and characteristics, something not included in the NPRM; performance standards for interference mitigation that would require that interference be terminated immediately upon notification to the operator; and meaningful penalties for non-compliance.
The ARRL noted that in the case of the Cedar Rapids, Iowa, interference complaint, BPL engineers spent 12 weeks vainly trying to eliminate interference. System operator Alliant Energy continued to operate, knowing its system was interfering, the League said.
"The interference was not eliminated until the test was prematurely concluded," the League pointed out.
The ARRL said it wants the FCC to provide for fines when willful interference occurs in violation of §333 of the Communications Act. And it wants the Commission to require BPL marketers to "give clear notice to potential customers that licensed radio services have priority and that the delivery of broadband service via BPL cannot be guaranteed." Consumers should have to sign off on that notice before contracting for BPL service, the League contends.
"Otherwise," the ARRL's letter said, "the labeling requirements of Part 15 fall into the category of meaningless boilerplate."
In
addition to Adelstein, ARRL representatives have met so far with Commissioners
Kevin J. Martin, and Michael J. Copps. The League hopes to meet with the
principal advisors to Chairman Michael K. Powell and Commissioner Kathleen Q.
Abernathy before the October 7 cutoff for ex parte communications in the
proceeding.
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