ARRL, FCC Continue BPL "Interference Resolution" Database Debate

NEWINGTON, CT, Dec 2, 2005--The acting chief of the FCC Office of Engineering and Technology (OET) is standing foursquare behind the recently opened Broadband over Power Line (BPL) Interference Resolution Web site. The deadline for BPL operators to populate the database, provided by the United Power Line Council (UPLC) and the United Telecom Council (UTC), was November 19. In October, the ARRL took strong exception to limitations UTC, the site's administrator, has imposed on the number of allowable licensee searches and to the use of ZIP codes as the only search key. Acting OET Chief Bruce Franca defended the BPL database November 22.

"Your concern, limiting access to the database, does not constitute a violation of the rules," said Franca, citing verse and chapter of Part 15 to back up his assertion. Franca said §15.615(d) "clearly states" that the database is intended to identify possible sources of harmful interference thought to emanate from a BPL system. "Permitting individuals who are using a licensed service that operates on the same frequencies as are used by a BPL system to query for pertinent information in the geographic area of that interference fully fulfills this function," he concluded.

A note on the BPL database site cautions that users are "allowed to search a limited number of times each month." It further advises users not to conduct random database searches, lest their access to the database be further restricted. In his initial complaint, ARRL CEO David Sumner, K1ZZ, called the notice "unacceptable" and characterized it as an attempt to "ration access" to the site.

Franca also defended the use of ZIP codes as the only means to query the database, saying they are easily understood and identifiable. "Database queries will provide the information required by our rules for BPL systems deployed within a ZIP code," he said. Sumner had argued earlier that requiring users to enter a ZIP code before gaining access to the database was "clearly contrary" to the requirement that the database be available to the public.

Responding November 30, Sumner gamely took another stab at getting the League's point across. Part 15 is unambiguous that the information in the database must be publicly accessible approximately 30 days before a BPL system begins operation, he said. Using a ZIP code to gain entry, Sumner continued, "renders the advance notification requirement meaningless to the public" unless someone were to regularly visit the Web site and repeatedly enter a particular ZIP code. But since that practice "is specifically discouraged by the UTC's notice," Sumner pointed out, it's impossible for the public to know about a BPL startup in advance, something the BPL Report and Order seems to require.

The lack of any prior consultation prevents a BPL operator from tailoring a system to reduce the probability of harmful interference to a specific station in advance of commencing operation, Sumner continued. "Therefore, the benefit of the prior notification requirement, limited though it is as an interference measure, is lost to the BPL operator as well as to the licensed radio service that will suffer harmful interference that could have been avoided," he said.

Sumner said the UTC-administered database "provides less than was promised" in the FCC's October 2004 Report and Order. "For advance notification to be meaningful, the public must know when additions and changes to the database occur," he contended. "That is functionally impossible if the 'publicly accessible' database is actually maintained behind an opaque curtain and is only revealed one ZIP code at a time."

One workaround, Sumner suggested, would be to require UTC to make publicly available a list of ZIP codes and the date of the most recent data entry for each. "This also would make it clear when a specific BPL system serves more than one ZIP code area, information that is required by §15.615(a)(3) but that is not available to the public at present except by individual query of each ZIP code."

Sumner said Franca failed to respond to his point regarding the error message that appears when a database user enters a ZIP code where no BPL system apparently has been deployed. As an example, he cited a small BPL test area that is located partly in Agawam (ZIP 01001) and partly in the community Feeding Hills (ZIP 01030), Massachusetts. The data for the system only appears under the Agawam ZIP code, Sumner pointed out.

Entering the Feeding Hills ZIP code yields the error message. At that point, users are asked to provide "written details" about the nature of the interference and the user's licensed operations as well as location--"complete address and coordinates"--operating frequencies, whether mobile or fixed and a brief description of the interference.

"Frankly, UTC has no authority to require the submission of such information from an FCC licensee prior to sharing information that the public is entitled to as a matter of right," Sumner concluded--reiterating a point made in his initial correspondence. "If the database were appropriately accessible the question would never arise."

Sumner copied his reply to the UTC President and CEO William R. Moroney.

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