ARRL

ARRL General Bulletin ARLB027 (2004)

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ARLB027 FCC Poised to Act on BPL Report and Order in mid-October

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ARRL Bulletin 27  ARLB027
From ARRL Headquarters  
Newington CT  September 24, 2004
To all radio amateurs 

SB QST ARL ARLB027
ARLB027 FCC Poised to Act on BPL Report and Order in mid-October

The FCC Office of Engineering and Technology (OET) will present a
draft 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 past experience with BPL field trials, the ARRL told
Adelstein, ''widespread BPL deployment at the existing Part 15
radiated emission limit will result in an unmanageable incidence of
interference.''

Arguing for a reduction in the radiated emission limit, the ARRL
said 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.''

Other points the ARRL has stressed in its meetings with Commission
members include:

* consider including the NTIA's recommendations to standardize
measurement procedures and to require that Access BPL systems be
certificated, not merely verified.

* requiring independent confirmation of rules compliance before a
BPL system is placed in operation.

* 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, including fines.

* 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.''

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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