The sPARC gap
Newsletter of the
Portland (Oregon)
Amateur Radio Club
(c) PARC, 2004
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| Volume 22 | April, 2004 | Number 4 |
| Past Issues Index |
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What is BPL?
PL is "broadband over the power line". An unlicensed RF emission permitted under FCC rules Part 15 occupying the spectrum of 1.8 MHz to perhaps 50 MHz or more. Current pilot implementations are typically some sort of spread spectrum. Their function is to provide data networking and connection to the Internet. Part 15 was originally developed for unlicensed intentional radiators that were geographically isolated, narrow band "point" sources operating occasionally for brief intervals at low power with inefficient antennas and having very limited range. Fully implemented BPL likely would result in geographically ubiquitous broadband large-scale radiators radiating continuously over virtually all populated areas of the United States.
This picture first appeared in last November's issue of the sPARC gap, as the push for BPL was first undertaken by the FCC. The radio in the picture was being operated mobile in Emmaus, PA, where BPL was being field tested.
Why Do The Power Companies Want It?
Power distribution companies appear to be viewing BPL as a means to:
1. Access time-of-day power consumption. This would enable raising power billing rates during periods of peak consumption.
2. Access consumer behavior information such as TV programs watched and/or any other information that a line connected consumer product could report. This information is marketable.
3. Provide ISP service. This puts a new face on power companies as telecommunication and information companies as well as providing internet service revenue.
Why Does The FCC Want It?
FCC has declared their promotion of this application as good for "the last mile" into unserved rural areas and good for competition. Some critics claim the same economics that make rural broadband by cable infeasible also exist for BPL. BPL may be good for competition. It most likely is good for the energy industry to which the current administration has strong ties. Finally, this is an election year and both parties are running very expensive campaigns.
Impact On Licensed Services
There is much agreement between FCC and the power distribution industry on this issue. Both have stated they believe interference to licensed services will be minimal and readily correctible. Some, perhaps many, of the 650,000 Amateur Radio and the 15,000+ other licensees may not be aware of FCC's intent. The National Telecommunications and Information Agency (NTIA), government's telecom agency, has expressed concern but they are a part of the administration. The Federal Emergency Management Agency (FEMA) has expressed concern but like NTIA, they have a limited voice. Amateur Radio has been the most vocal primarily through ARRL but also through individual comment to FCC on the NOI by several thousand amateurs. Strong evidence exists from the current trials that BPL will create a noise floor of at least S9 in nearby receivers in any frequency band not "notched out". Power lines are good antennas for frequencies above 1 MHz.
BPL Susceptibility
Less attention has been paid to the probability of licensed transmitters interfering with BPL. BPL access nodes within the vicinity (one mile?) of an amateur antenna that is close (30 meters) to an overhead power line can be obliterated (front end overload) by amateur transmissions. One of FCC's favorite interference "fixes" is notching but this will not prevent front end overload as the BPL receiver would need to have adjacent channel rejection of at least 140 dB. That is not feasible using today's technology. This may not be a deal killer for the power companies since this interference will only affect the ISP function. Meter readings and "big brother" consumer behavior reporting have very low data rate requirements and could be transmitted multiple times to achieve error correction.
The Ecology Of BPL
To potentially divert the primary use of the entire RF spectrum capable of direct point-to-point communication between randomly located geographic positions around the globe to an application needing communication between a relatively limited number of geographic positions which could be and already substantially are served by alternative non-spectrum polluting means is a travesty not unlike cutting down all the trees in the hope the wooden house industry can build even more wooden houses in a land blessed with an abundance of alternative building materials.
The Nature Of The Struggle
BPL is allowed under current Part 15 regulations. The purpose of this action, as stated by FCC, is to find and define changes to Part 15 that will encourage and support its rapid adoption. Amateur radio HF privileges may be viewed as a significant deterrent to that rapid adoption. Altering those privileges may be viewed by some as an obvious fix. One of Michael Powell's recent comments on interference to licensed services was, "we will not allow disruption of essential services", or words to that effect. Does he consider amateur radio an essential service? We are in the midst of a political struggle in which the amateur community has argued primarily with technical facts and reasoning. ARRL has done an exemplary job in this area. The technical approach is most certainly necessary but it is not likely sufficient. Greg Walden (WB7OCE), US representative for the Second District in Oregon, is one of two amateurs in the US Congress and a sponsor of the "Amateur Radio Spectrum Protection Act". This act would require FCC to allocate new spectrum to Amateur Radio of equivalent utility and with equivalent privilege to replace any it removes or causes to be unusable. This should have the practical effect of preventing FCC from making significant change. Greg is concerned about BPL and several of us are working with his office in the hope of aiding his attempt to put congressional pressure on FCC. The BPL movement underscores the need for the Amateur Radio Spectrum Protection Act.
The Relationship Of BPL To The "Amateur Radio
Spectrum Protection Act"
Passing the "Amateur Radio Spectrum Protection Act" would conceivably be more important to us than separately containing BPL since its passage would put great pressure on FCC to contain BPL interference. This bill has two problems. The first is that it may come too late to prevent substantial BPL implementation; the bill would not likely be retroactive. The second problem is a lack of constituents. Who cares about amateur radio other than amateurs? Containing BPL has potential constituents; they are: other licensee's including TV broad-casters (NAB), the EMC community, international treaty organizations, emergency and relief organizations, cable service providers, the media and right to privacy advocacy groups to name a few. But try we must. This bill needs our support. House and Senate versions of this bill are identical and available on the ARRL website by using its search function.
What Will Happen Next?
Most FCC proceedings follow a similar path starting with a "Notice of Inquiry" (NOI) with a period of time to submit comments on the NOI and a subsequent period of time to submit comments on the comments submitted. After a period of deliberation, FCC may decide to Issue a "Notice of Proposed Rulemaking" (NPRM) also with a period of time to submit comments and a subsequent period of time to submit comments on the comments submitted. After another period of deliberation, FCC may decide to issue pertinent new regulations. This step is called Report and Order" (RO) and is the end of the proceeding. BPL is currently in the NPRM comment period. Comments are due Mon-day, May 3, 2004. Comments on submitted comments are due Tues-day, June 1, 2004.
The Role Of ARRL
ARRL has provided comprehensive technical and administrative comment on the NOI and will undoubtedly respond in kind on the
NPRM. These comments will carry more weight if joined by many amateurs and other licensees. One of FCC's "golden rules" these days is "let the marketplace decide". ARRL's strategy appears focused on
"...support the FCC's proposals as far as they go (remember, they're better than the status quo), to document exactly how they fall short of providing the protection that over-the-air services--especially the Amateur Radio Service--need and deserve, and to provide specific proposals for improvement...", with the ultimate hope that once BPL proponents appreciate the cost and probability of achieving success, they will decide to abandon it.
What Can Amateurs Do?
We can go on record with our views by filing comments on the BPL NPRM and by writing our congressmen requesting they cosponsor the "Amateur Radio Spectrum Protection Act".
You can get started by going to the ARRL website home page (www.arrl.org) and reading the
QST article by David Sumner "It Seems to Us... BPL: What Now?" and the article below it
"ARRL Encouraging Thoughtful, Considered Comments on Proposed BPL Rules". If you have the time, read the NPRM (38 pages). Pay particular attention to test and verification methods which could be changed to effectively increase peak power. If you do not have the time for this reading, submit your comments based upon what you already know. But
do submit comments. Copy your comments to our senators. Contact information for Smith and Wyden is below. They are "at large." Also copy your comments to your Representative. Contact information for the House of Representatives is below. And finally copy your comments to Representative Greg Walden. He needs testimonials to push the Amateur Radio Spectrum Protection Act forward.
ARRL has cautioned that "sour grape" comments will not advance our cause and comments suggesting that BPL simply will not work will have no impact in this response-to-FCC process. They recommend thoughtful constructive comments to improve the application and deal with anticipated problems. Nonetheless, I intend to include in my comments that I consider BPL a flawed concept. I have not as yet formulated my comments but I expect they will focus on area-by-area
in-situ testing and requiring that licensed services be permitted to participate in this testing from start to finish. I think we need a limit on noise floor increase, perhaps one S unit (6 dB) except in those cases where the noise floor is already four or more S units in which case no increase would be allowed in order to prevent cumulative increase. This would be a very tough requirement and it suggests "mapping" noise floors in areas prior to testing installations. We will also need a funded timely and effective interference resolution process. There will not be enough Riley Hollingsworth to deal with all the complaints that surely will result.
The deadline to file BPL comments is Monday May 3, 2004. Comments on submitted comments are due Tuesday, June 1, 2004. See filing information below.
Spectrum Protection Act
We can express our concern for amateur radio and our support for passage of the "Amateur Radio Spectrum Protection Act" by writing to our congressmen, making sure to copy Greg Walden. The House and Senate Bills, which are identical, are available on the ARRL website using its search function.
Use HF
The surest way to lose this privilege is to not use it.
National E-mail Petition On BPL
Perhaps more on this later.
Additional information about BPL and Amateur Radio is on the ARRL Web site:
http://www.arrl.org/tis/info/HTML/plc/
Spectrum Policy
BPL may just be the tip of the iceberg. Both FCC and NTIA have extensive efforts underway to examine how they do business. At FCC this program is called the "Spectrum Policy Task Force". Look at:
http://www.fcc.gov/sptf/
"All consumers . . . deserve a new spectrum policy paradigm that is rooted in modern-day technologies and markets. We are living in a world where demand for spectrum is driven by an explosion of wireless technology and the ever-increasing popularity of wireless services. Nevertheless, we are still living under a spectrum 'management' regime that is 90 years old. It needs a hard look, and in my opinion, a new direction."
- Chairman Michael K. Powell,
Broadband Migration III: New Directions in Wireless Policy, Remarks at the Silicon Flatirons Telecommunications Program, University of Colorado at Boulder, October 30, 2002.
Like it or not, amateur enthusiasts will have to become politically active to avoid losing privileges.
-K7GWP
Contact/Filing Information
The NPRM is available on the FCC Web site in Microsoft Word format:
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-29A1.doc or as an Adobe PDF file:
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-29A1.pdf
You may file detailed comments on the BPL NPRM via the main FCC's Electronic Comment Filing System
(ECFS): http://www.fcc.gov/cgb/ecfs/
The FCC also is accepting brief comments on the BPL NPRM via its ECFS Express page
http://gullfoss2.fcc.gov/ecfs/Upload/
ARRL provides the following additional filing instructions:
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.
US Senate: http://www.senate.gov/general/contact_information/senators_cfm.cfm?State=OR
Smith, Gordon - (R - OR) Class II 404 RUSSELL SENATE OFFICE BUILDING WASHINGTON DC 20510 (202) 224-3753 Web Form:
gsmith.senate.gov/webform.htm
Wyden, Ron - (D - OR) Class III 516 HART SENATE OFFICE BUILDING WASHINGTON DC 20510 (202) 224-5244 Web Form:
wyden.senate.gov/contact.html
US House:
http://www.house.gov/MemStateSearch.html
Representatives: David Wu - 1st District, Greg Walden - 2nd District, Earl Blumenauer - 3rd District, Peter DeFazio - 4th District, Darlene Hooley - 5th District. Find your Representative District at
www.bluebook.state.or.us, click "National" tab, then "US Representatives"
Greg Walden (WB7OCE) US Representative Second
Congressional District of Oregon, House Committee on Energy and Commerce, Committee on Resources, Deputy Whip.
www.walden.house.gov. Greg has requested we communicate with him on BPL issues through his Legislative Director, Brian Hard. His Email address is:
Brian.Hard@mail.house.gov