NEWINGTON, CT, Mar 24, 2004--The ARRL will comment by the deadline on the FCC's proposals to amend its Part 15 rules to adopt new requirements and measurement guidelines for so-called "Access BPL" systems that provide broadband access via electric utility power lines. Comments are due May 3. The deadline for reply comments is June 1. ARRL CEO David Sumner, K1ZZ, says the League recommends that members read the FCC's Broadband over Power Line Notice of Proposed Rule Making (NPRM) in ET Dockets 03-104 and 04-37, then develop their own thoughtful, considered comments. The ARRL advocates filing comments that specifically address the FCC's BPL proposals, reflect positively on the amateur community and, if possible, offer alternative recommendations.
"It's important to remember four things," Sumner said. "First, this is not a proceeding to 'permit' or 'authorize' BPL. BPL is already permitted under the existing Part 15 rules. Second, the NPRM reaffirms the important principle that licensed services must be protected from harmful interference and are not required to protect BPL systems; this is good, but we can't take it for granted nor can we assume that the principle will be honored in practice."
"Third," Sumner went on, "the NPRM proposes additional, new constraints on BPL to protect licensed services. The FCC did not go far enough, but at least the proposals aim in the right direction."
"Finally, while we continue to believe firmly that BPL is a very bad idea, arguing that the FCC should 'ban BPL' will not get us anywhere." Sumner says that instead, amateurs must document beyond any doubt the levels of protection that must be given to over-the-air services, then leave it for others to decide whether BPL is feasible within those limits.
"We need to prove that the risk of interference is significantly greater than the BPL proponents say it is," Sumner continued. "There is far more evidence of that now than there was when the FCC opened its Notice of Inquiry last April."
Sumner also asserted that the FCC's proposed "interference mitigation" requirements fall far short of providing real protection from harmful interference, and that the Commission is ignoring the practical problems that will arise when Amateur Radio transmissions disrupt BPL systems.
BPL and the FCC Rules
Access BPL is a form of carrier current or power line carrier (PLC) communication. It would apply RF in the HF to low-VHF range to existing low and medium-voltage exterior power lines to distribute Internet and broadband services. It was the aspect of feeding RF signals into outdoor power lines that initially raised Amateur Radio concerns regarding potential interference.
Carrier current systems are subject to the FCC's Part 15 rules governing unlicensed devices, and the FCC has acknowledged that "amateur operations are likely to present a difficult challenge" to BPL deployment, especially in the case of hams--an estimated 150,000 of them--who use high-gain antennas sited near power lines. The proposed rules remain silent on the issue of mitigating BPL interference to the estimated 70,000 Amateur Radio HF mobile stations.
"Interference Mitigation"
At the February 12 FCC open meeting where the NPRM was adopted, Commission staff spoke of requiring that the BPL industry maintain a database accessible to the public to assist in locating BPL system operators. However, the actual proposals contained in the NPRM do not mandate a publicly accessible database. "These and other shortcomings must be resolved in order for interference mitigation to be an acceptable strategy in the case of fixed stations," Sumner said.
The League also wants the FCC to establish performance standards for BPL interference mitigation. "To offer any real protection to licensed services, the rules must require that interference be resolved immediately," he said. "There must be severe enforcement penalties for failure to resolve a complaint in real time and for failure to maintain the database."
Interference mitigation for mobile stations "is clearly is impractical," Sumner asserted. "Since BPL systems operating at the present Part 15 limit cause harmful interference to mobiles, the only solution is an absolute limit on radiated emissions that is lower than the present limit. We are in the process of determining scientifically what that limit must be."
Interference Reports Wanted!
The League especially encourages anyone, particularly radio amateurs, who has actually experienced BPL interference to file detailed comments documenting the interference. "It is extremely important that anyone who has suffered interference that is confirmed to have been caused by BPL to get their experiences into the record, in detail," Sumner said. "BPL proponents claim they are not getting interference complaints. If we let them claim their systems are 'clean' when we know they aren't, shame on us."
Sumner said the League also will continue to encourage "affected interests outside the amateur community" to comment. The League urges anyone who opposes BPL to file comments, either supporting the ARRL's comments or by offering their own arguments.
Commenting on this NPRM
The deadline to file comments is Monday, May 3. Reply comments are due Tuesday, June 1. Interested individuals and organizations may file comments via the Internet using the FCC's Electronic Comment Filing System (ECFS). The FCC asks that anyone filing comments on this NPRM do so "only in the newly established ET Docket No 04-37," the FCC said March 22 in a public notice, not in the NOI proceeding, Docket No 03-104.
Commenters should include their full name, US Postal Service mailing address and ET Docket No 04-37 when completing the transmittal screen. The FCC also is accepting brief comments on this proceeding via its ECFS Express system. The BPL proceeding is the top item on the list.
Parties may also submit electronic comments via e-mail. To learn how, e-mail the ECFS ecfs@fcc.gov and include the words "get form <your e-mail address>" in the body of the message.
When submitting a comment or viewing filed comments, ECFS users should type "04-37" (without quotation marks but including the hyphen) in the "Proceeding" field of the ECFS on-line form. Do not use the NPRM's FCC document number when filing or searching for comments. The ECFS permits attaching a file containing detailed comments prepared off-line.
For additional information on filing comments
on this NPRM, see the FCC
public notice.
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