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 Previous: The K7RA Solar Update |  Next: US Coast Guard Auxiliary special event set |
NEWINGTON, CT, Oct 28, 2004--The FCC today released the full BPL Report and Order (R&O) it adopted just two weeks ago. While extolling the purported benefits of broadband over power line technology, the 81-page document also declares the FCC's intention to "protect licensed services from harmful interference." In line with remarks made at the October 14 open meeting where the FCC adopted the R&O--then still in draft form--the FCC will require BPL operators to address and resolve all valid interference complaints. It declined, however, to reduce the Part 15 radiated emission limit for BPL systems, maintaining that emissions from BPL systems are very localized and at low enough levels to preclude harmful interference in the first place. And it left the door open to possibly upping the limit in the future. When interference does occur, the Commission favors "notching," frequency shifting and power reduction by BPL systems as the preferred mitigation modes.
"We recognize that some radio operations in the bands being used for Access BPL, such as those of Amateur Radio licensees, may occur at distances sufficiently close to power lines as to make harmful interference a possibility," the FCC conceded in its R&O. "We believe that those situations can be addressed through interference avoidance techniques by the Access BPL provider such as frequency band selection, notching, or judicious device placement."
Notches would have to be at least 20 dB below applicable Part 15 limits on HF and at least 10 dB below Part 15 limits on VHF. The FCC called the ability to alter a system's operation to notch out transmissions on specific frequencies where interference is occurring "a necessary feature for resolving interference without disrupting service to BPL subscribers."
FCC Advises Hams to Take Steps to Avoid Interference
The FCC said it had no evidence before it that BPL operation would significantly contribute to generally raising background noise levels. At the same time, it seemed to put some of the onus on Amateur Radio licensees to take steps to avoid power-line interference--and, by inference, BPL interference--in advance.
"In addition, because power lines inherently can radiate significant noise emissions as noted by NTIA and ARRL, good engineering practice is to locate sensitive receiver antennas as far as practicable from power lines," the FCC said. In a footnote, the FCC took pains to advise ARRL that in cases where its members experience RF noise, "such noise can often be avoided by carefully locating their antennas; in many instances an antenna relocation of only a relatively short distance can resolve noise interference."
No Special Protections for Amateurs
BPL operators would be required to notch certain bands, such as those used for life and safety communications by aeronautical mobile or US Coast Guard stations. The FCC R&O makes clear, however, that similar rules will not apply to the Amateur Service, although notching could be one mitigation tool to deal with ham radio complaints.
"We similarly do not find that Amateur Radio frequencies warrant the special protection afforded frequencies reserved for international aeronautical and maritime safety operations," the Commission said, adding that in many instances, amateur frequencies are used for routine communications and hobby activities.
"While we recognize that amateurs may on occasion assist in providing emergency communications," the FCC said, "we believe that the general Part 15 provisions and the specific provisions being adopted herein for Access BPL operations are sufficient to protect these amateur operations."
BPL's Upside Outweighs Downside, FCC Suggests
Although some cases of harmful interference may be possible from BPL emissions at levels up to Part 15 limits, the FCC said, "we agree with NTIA [National Telecommunications and Information Administration] that the benefits of Access BPL service warrant acceptance of a small and manageable degree of interference risk." The Commission reiterated in the R&O its belief that BPL's public benefits "are sufficiently important and significant so as to outweigh the limited potential for increased harmful interference that may arise."
The FCC also said that while it agrees with the ARRL that BPL is not a "traditional point-source emitter," it doesn't buy into the notion that BPL devices "will cause the power lines to act as countless miles of transmission lines all radiating RF energy along their full length."
Additional Provisions
Among other specific provisions, the FCC's new rules also mandate certification of BPL equipment instead of the less-stringent verification, a requirement for a public BPL database--something the BPL industry did not want. They also require mechanisms to deal swiftly with interference complaints.
BPL systems will have to incorporate the ability to modify operation and performance "to mitigate or avoid potential harmful interference to radio services and to deactivate specific units found to actually cause harmful interference that cannot be remedied through modification of their operation," the R&O says.
The public BPL database would have to include the name of the BPL provider, the frequencies of BPL operation; the postal ZIP codes the BPL system serves; the manufacturer and type of BPL equipment and its associated FCC ID number; the contact information, including both telephone number and e-mail address of a person at or associated with the BPL operator to facilitate interference resolution (phones would only have to be staffed during "normal business hours," the FCC specified), and the proposed or actual date of BPL operation.
Further, the new rules spell out the locations of "small geographic exclusion zones" as well as excluded bands or frequencies--concessions made primarily at the insistence of the NTIA, which administers radio spectrum for federal government users--and "coordination areas" where BPL deployments at any frequency must be "precoordinated by BPL operators." They also detail techniques to measure BPL emissions from system equipment and power lines.
No Change in Approach to Part 15 Complaint Resolution
The FCC's R&O makes clear that the agency does not intend to deal with interference complaints regarding BPL systems any differently, nor any more stringently, than it does interference complaints involving other systems that fall under §15.5(c) of its rules.
"Under this rule, parties who believe they are experiencing interference from an unlicensed device are first expected to bring the matter to the attention of the operator of the unlicensed device," the FCC said. "If that action does not resolve the interference, the party may then seek intervention by the Commission."
The FCC further said it expected "good faith" on both sides in resolving any interference complaints that might arise. "Speedy resolution of interference will not result if the database information on Access BPL deployments is abused, and the BPL operators are deluged with frivolous interference complaints," the FCC said
The Commission added that it expects BPL operators to take every interference complaint seriously and to diagnose the possible cause of interference quickly. But it suggested that complainants have responsibilities as well.
"At the same time, we expect the complainant to have first taken reasonable steps to confirm that interference, rather than a receiver system malfunction, is occurring and, to the extent practicable, to determine that the interference source is located outside the complainant's premises," the Commission said.
The FCC pledged to investigate complaints that land in its lap and take action against the BPL operator if it is found to be causing harmful interference. "If, on the other hand, the Commission uses its resources to investigate an interference complaint that is found to be frivolous, the Commission will impose appropriate sanctions for abuse of its administrative process."
Shutting down a BPL system in response to a valid interference complaint "would be a last resort when all other efforts to satisfactorily reduce interference have failed," the FCC said. It did require BPL systems to incorporate a means to allow deactivation of individual components on a remote-controlled basis, but it emphasized that only the FCC may direct a BPL system to cease operation.
ARRL Mulling Options
ARRL officials are studying the R&O and considering possible responses. Meeting October 16 in Dallas, Texas, the ARRL Executive Committee (EC) authorized the filing of a Petition for Reconsideration in response to the BPL R&O in ET Docket 04-37. The EC also authorized ARRL General Counsel Chris Imlay, W3KD, to "prepare to pursue other available remedies as to procedural and substantive defects" in the BPL proceeding.
For more information on BPL, visit the "Broadband Over Power Line (BPL) and Amateur Radio" page on the ARRL Web site.
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