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NEWINGTON, CT, Oct 14, 2005--The new Broadband over Power Line (BPL) Interference Resolution Web site provided by the United Power Line Council (UPLC) and the United Telecom Council (UTC) now is open. But the ARRL has taken strong exception to limitations the site's administrator, UTC, appears to be imposing on the number of allowable licensee searches. A note on the Web site cautions that each licensee "is allowed to search a limited number of times each month" and advises them not to conduct random database searches lest their access to the database be further restricted. ARRL CEO David Sumner, K1ZZ, said the provision is inappropriate and the database fails to meet the letter or spirit of the Part 15 BPL rules.
"This notice is totally unacceptable to the ARRL and should be equally unacceptable to the Commission," Sumner said today in a letter to FCC Office of Engineering and Technology Acting Chief Bruce A. Franca. Sumner noted that the new Part 15 rules speak of a "publicly available" and "publicly accessible" database. "It is unacceptable for the database operator to attempt to discourage the public from making full use of the database by threatening to ration access," he asserted.
The FCC this week formally announced its designation of UTC as the Access BPL database manager as mandated under Part 15 regulations governing BPL that the Commission adopted one year ago today. The regulations spell out specific interference-mitigation requirements for BPL systems and mandate the new "BPL notification" database. The database is designed to provide information for FCC licensees to contact operators of BPL systems in their areas that may be the source of harmful interference.
Part 15 requires the database to include the name of the Access BPL provider; frequencies of operation; postal ZIP codes served by the specific BPL operation; the manufacturer and type of equipment and its associated FCC ID number; contact information, including both phone number and e-mail address of a person to facilitate the resolution of interference complaints, and the proposed and/or actual date of Access BPL operation. BPL operators have until November 19 to comply.
ARRL Takes Issue with Requiring ZIP Code to Access
Requiring users to enter a ZIP code before gaining access to the database "is clearly contrary" to the requirement that the database be available to the public, Sumner said. "All of this information must be accessible and available to the public without having to enter a ZIP code," he contended in his letter to Franca. "The ZIP code is simply one element in the database, not the basis on which access to the remaining information may be restricted. There can be no restriction to the public's access to any of the information contained in the database."
FCC rules require that BPL system operators supply information for the database no later than 30 days prior to initiation of service. The information must be available to the public no more than three business days later. Sumner argues that making the database searchable only on the basis of ZIP code conflicts with the advance notification requirement.
"The clear intent of the rules is to require at least 25 days (30 days minus three business days minus a weekend) of advance public notice of an Access BPL system being activated," Sumner told Franca. "This advance notice is required so that licensees may document the radio frequency environment prior to activation of the BPL system. For the information to be available only in response to the entry of a ZIP code renders the advance notice requirement meaningless and blocks the achievement of the objectives for advance notice" spelled out in the FCC's October 14, 2004, BPL Report and Order.
Sumner said the inadequacy of the ZIP code requirement is further illustrated if a user happens to enter a ZIP code that apparently does not match the database. This yields the message "No BPL Operations Found in Your Area," and directs the user to contact the UPLC, providing written details concerning the nature of any interference and of the user's licensed operations, "including the location (complete address and coordinates), frequency(ies) of operation, the type of operation (mobile or fixed) and a brief description of the interference." The page also provides the FCC's definition of "harmful interference."
"This, too, is unacceptable," Sumner wrote. "UTC apparently intends to restrict the availability of information to the public according to its own definition of 'need to know.'" He said no FCC licensee or other radio user is obligated to share such information with a third party, "and most certainly not as a condition of access to information that is required by FCC regulations to be available to the public."
Sumner called on Franca to immediately inform UTC to revise and correct its BPL database system and bring it into full compliance with Part 15 no later than November 19.
Because ARRL is operating a Motorola Powerline LV BPL system at W1AW in cooperation with the manufacturer, the League is a BPL operator under Part 15. The ARRL will be requesting a user name and password for administrative access to the database.
The Office of Management and Budget approved the information-collection requirements the new Part 15 rules contain, and the amendments to §15.615(a) through (e) became effective July 22, 2005. The BPL database, which currently appears to contain no actual data, is open and requires no registration or login. Users experiencing problems in accessing the database should contact the UTC database administrator; 202-872-0030.
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