CLOSING COMMENTS from Monitoring Times June 2004 Edition

Broadband Over Power Lines By Rachel Baughn, KE4OPD, Editor

Broadband Over Power Lines (BPL) is a high speed, 2-26 MHz, data transmission system that uses the power line as a conductor. It is being touted (mistakenly, we believe) as a cost-effective means to bring Internet access to rural households. It is of concern to MT readers because the unshielded power line will radiate and likely cause interference to HF and low VHF reception. The FCC's Notice of Proposed Rule Making (NPRM) on Broadband over Power Line (BPL) systems, ET Docket No. 04-37, invites comments on the proposed procedure to mitigate interference when it inevitably occurs.

The current deadline for reply comments is June 1. We urge readers to educate themselves on this issue of particular concern to shortwave listeners and amateur radio operators.

Thanks to the hard work of the Amateur Radio Relay League (http://www.arrl.org) and Joe Buch N2JB and others from the North American Short Wave Association (http://www.anarc.org/naswa) for providing the following points to aid in your argument to the FCC.

It is important to understand that no additional rules or permission are required to allow BPL to operate under existing FCC rules. The NPRM is simply proposing procedures to allow victims of interference to get the BPL service to "mitigate" the interference. Your comments need to be directed to why such solutions are incomplete and what additional rules need to be adopted before the promised protections are effective.

Amateur Radio

The proposed rules do make it clear that interference to licensed operators, including hams, will not be tolerated. However, the rules are weak on implementation and enforcement:

The current rules do not offer any practical protection for mobile amateur radio stations. The interference to mobile stations could not be identified, the interfering BPL operator found, and adaptive steps taken quickly enough to be of practical use to the mobile amateur operator.

Therefore, radiation emission standards should be set sufficient to protect mobiles, and BPL systems should be tested for rules compliance by an independent laboratory prior to initiation of service.

Standards should be set for interference mitigation: mitigation should be available 24/7 and should be immediate upon receipt of a complaint. To aid in identifying and reporting interference, the BPL database must be readily accessible to the public and kept up to date.

To ensure an informed marketplace, marketers of BPL services must give clear notice to consumers that licensed radio services have priority and that the delivery of BPL services therefore cannot be guaranteed. Because of the potential for severe, wide-area interference, there must be severe penalties for non-compliance with these rules.

Shortwave Listeners

Any interference to international broadcasting is illegal under both international radio regulations and the FCC's own Part 15 regulations that require that interference must be promptly terminated. The FCC's proposed procedure for interference mitigation is impractical for the listening public for the following reasons:

The burden of proof will be on the unskilled listener to demonstrate to the BPL provider or the FCC enforcement function that the interference claim is valid. The spectral signature of BPL interference will be different for each type of modulation, since the FCC has not standardized the modulation format. To expect unskilled listeners to prove that BPL is the cause of their interference problem is unreasonable and impractical.

Many international broadcast listeners use portable receivers when traveling around the USA. As with mobile ham operators, such listeners cannot be expected to know the contact information for reporting BPL interference in each area and certainly not fast enough for timely mitigation.

Many international broadcast listeners are tourists, foreign students or immigrants to this country with limited English language ability who use shortwave radios to listen to foreign broadcasts in their native language. Identifying, locating, and reporting BPL interference is asking too much of people who are not proficient in BPL technology, the English language, or FCC bureaucratic procedures.

In theory, once notified, the BPL service provider must quickly move the energy to a frequency that does not cause interference to the entity that complained. Of course the energy may then interfere with another user of the spectrum who will then complain.

International broadcasters change frequencies according to time of day, season of the year, and time within the eleven-year solar sunspot cycle. The proposed rules would require prompt response to interference complaints to frequencies which do not remain static.

In addition to mandating that mitigation be available 24 hours per day and 7 days per week, and that substantial penalties be put in place (NASWA suggests $10,000 per day), the FCC should also establish a specific response time for interference complaints to be resolved before penalties are invoked.

The FCC does not propose any third party entity to arbitrate disputes. It is likely that the enforcement function will fall to the FCC, which has neither the staff nor the budget for timely or effective investigation and resolution.

How to Comment

Readers are encouraged to submit their comments; there is strength in numbers Even though an organization representing many members may file, that filing counts as only one comment.

Before filing, read the NPRM at: http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6515783486
(or just go to http://www.arrl.org, click on story "ARRL Encouraging "Thoughtful, Considered" Comments on Proposed BPL Rules" and follow links to the document and other background stories)
You can submit your comments electronically via the web at: http://www.fcc.gov/cgb/ecfs/

Under ECFS Main Links, click on "Submit a Filing." In the "Proceeding" field, enter "04-37" and complete the required field. Comments may be typed into a form or you may attach a file. Comments also may be submitted via e-mail, per instructions.

If you have to file comments in writing, send an original and four copies to: Commissioner's Secretary, Office of the Secretary, Federal Communications Commission, 445 12th Street, SW, Washington, D.C. 20554. Make sure the subject clearly states it is a response to ET Docket No. 04-37. All responses should be received by the FCC by June 1, 2003.

For additional technical background, we recommend http://www.ARRL.org/tis/info/HTML/plc/

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