A BPL extractor in Cedar Rapids, Iowa.
NEWINGTON, CT, Jun 24, 2004--The ARRL says the FCC apparently has already made up its mind about broadband over power line (BPL) and "wants no bad news" about the technology. In reply comments filed June 22 on the FCC's Notice of Proposed Rule Making in ET Docket 04-37, the League called on the Commission to take "a fresh look" at BPL before enabling its deployment. Again asking the FCC to put the proceeding on hold for a year, the League recommended that the Commission in the meantime require BPL providers to conduct FCC-monitored interference testing with all stakeholders. The ARRL charged that while an overwhelming majority of comments oppose BPL due to interference concerns, the FCC continues to rely on what the League called "vacuous assurances that BPL would not cause harmful interference." Test data and a growing record of unresolved complaints indicate otherwise, the ARRL said.
A BPL extractor in Cedar Rapids, Iowa. |
"ARRL is of the view that this proceeding has been prejudged and will, in the end, be decided not on the technical issues that should control the outcome of this proceeding, but on the politics of the matter," the League commented. "Given the evidence on the Commission's table, it cannot now authorize BPL at the radiated emission levels proposed, and without substantial restrictions."
Among those restrictions, the League recommended keeping BPL altogether away from all Amateur Radio allocations, should the FCC decide to authorize BPL under its proposed rules. As an alternative, the FCC should guarantee that an interfering BPL system can be shut down immediately in the face of a valid complaint, "not after a BPL provider has taken months to discover that the interference cannot be resolved."
Where There's Smoke . . .
To date, the ARRL contended, the FCC has seemingly ignored the League's BPL technical studies as well as the National Telecommunications and Information Administration (NTIA) Phase 1 BPL study that clearly demonstrate BPL's interference potential. Five additional technical evaluations accompanied the ARRL's reply comments.
"The Commission is obligated by the Administrative Procedure Act to look for fire where it is shown a good deal of smoke," the League said. "Here there is far more than smoke in the record." Any decision in the BPL proceeding "must be supported by substantial evidence," the ARRL asserted.
To bolster its case, the ARRL pointed to the Boeing Company's comments. Boeing told the FCC that Commission-proposed interference mitigation techniques "are inadequate to protect safety of life aeronautical HF communications services." The aircraft manufacturer urged the FCC to "carefully investigate these issues" before adopting rules to authorize BPL networks in spectrum used by aeronautical HF radio services.
"To permit BPL on the current record is to risk the lives of passengers and crew aboard aircraft," the ARRL rejoined. "The Commission simply cannot jeopardize the lives of passengers and crew of aircraft solely to rush to judgment on an untested competitive broadband alternative which uniquely has an established interference potential."
The ARRL also cited the comments of the Missouri State Highway Patrol, which note a lack of comprehensive testing to validate FCC assertions of BPL's low interference risk. The law-enforcement agency called the FCC-suggested interference mitigation techniques "reactive, not proactive" and said interference to its low-band VHF systems could prevent communication during a crisis "where injury or death might be the result of a reduction in communications ability."
NTIA: Studies vs Comments
The League said the results of both its studies and the NTIA's "are entirely consistent." Referring to the NTIA Phase 1 analysis, the ARRL said it's "quite reasonable to assume that the interference potential of BPL systems to fixed HF Amateur Radio stations is on the order of 460 meters (approximately 1509 feet) from the nearest BPL device." No proposals address BPL interference mitigation for mobile stations, the ARRL noted.
While commenting extensively on--and in some instances agreeing with--the NTIA's late-filed comments, however, the League said they depict an agency that must "balance dual and, in this case, conflicting roles" as the White House telecommunications policy advocate. The NTIA's comments, the ARRL asserted, reflect the Administration's broad overall policy, not the interference potential of BPL.
 The QTH of Jim Spencer, W0SR. BPL-carrying power lines are visible in the background. |
The League questioned the NTIA's contention that BPL is a "win-win" situation and that its potential public benefits and alleged capability to minimize power line noise argue for "accepting a degree of interference risk."
"Not so," the ARRL countered. "Licensed radio services operating in the sensitive HF environment should not have foist upon them a substantial interference risk from unlicensed devices or systems whatsoever." The NTIA suggested that BPL deployment would lead to improvements in the associated low and medium-voltage power distribution systems, thus reducing power line noise. "Replacing one interference source with another in the same bands is not in any way beneficial," the ARRL responded.
Unresolved Complaints
The ARRL also took the FCC to task for neglecting to acknowledge or respond to a mounting number of interference complaints, most from amateur licensees living in BPL field trials areas. "The Commission has, as of this writing, adjudicated not a single one and has ignored repeated requests from licensed radio amateurs for even a confirmation of receipt of their complaints!" the ARRL emphasized. BPL noise in some instances has precluded amateur operation, the League said. Earlier this month, the ARRL filed a well-documented and supported complaint on behalf of Jim Spencer, W0SR, in Cedar Rapids, Iowa. The League suggested such BPL complaints deserved careful analysis, but not the Commission's cold shoulder.
"What ARRL is unwilling to tolerate is the continuation of the Commission's sweeping of these complaints 'under the rug,' which is exactly what has happened in this proceeding," the League commented. The Commission must put its zeal over BPL aside and "take a fair look at them before any action is taken in this proceeding."
The League also questioned why BPL interference complaints to the FCC were ending up in the Commission's Office of Engineering and Technology instead of the Enforcement Bureau.
Proposed Rules Provide Little Protection
The ARRL didn't spare BPL operators. "The level of accountability demonstrated to date by operators of BPL test sites is dismal and unacceptable," the League said. It expressed little confidence in utilities that have failed to resolve power line noise complaints from amateurs to do any better with BPL complaints.
Based on the current record, the ARRL argued, proposed radiated emission levels for BPL are too high. "The Commission has not proposed any rules which would predictably and reliably protect HF and low-band VHF radio systems from interference," ARRL concluded. "The interference resolution mechanisms that are adopted should be real, rather than merely illusory."
For additional information, visit the "Broadband Over Power Line (BPL) and Amateur
Radio" page on the ARRL Web site. To support the League's efforts in this
area, visit the ARRL's secure BPL Web
site.
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