ARRL, FCC Continue BPL Interference Resolution Database Debate:

The acting chief of the FCC Office of Engineering and Technology (OET) is standing foursquare behind the recently opened Broadband over Power Line (BPL) Interference Resolution Web site http://www.bpldatabase.org/. The deadline for BPL operators to populate the database, provided by the United Power Line Council (UPLC) and the United Telecom Council (UTC), was November 19. In October, the ARRL took strong exception to limitations UTC, the site's administrator, has imposed on the number of allowable licensee searches and to the use of ZIP codes as the only search key. Acting OET Chief Bruce Franca defended the BPL database November 22.

"Your concern, limiting access to the database, does not constitute a violation of the rules," said Franca, citing verse and chapter of Part 15 to back up his assertion. Franca said §15.615(d) "clearly states" that the database is intended to identify possible sources of harmful interference thought to emanate from a BPL system. "Permitting individuals who are using a licensed service that operates on the same frequencies as are used by a BPL system to query for pertinent information in the geographic area of that interference fully fulfills this function," he concluded.

A note on the BPL database site cautions that users are "allowed to search a limited number of times each month." It further advises users not to conduct random database searches, lest their access to the database be further restricted. In his initial complaint, ARRL CEO David Sumner, K1ZZ, characterized the notice as an attempt to "ration access" to the site.

Franca also defended the use of ZIP codes as the only means to query the database, saying they are easily understood and identifiable and will provide the information the rules require on BPL systems deployed within a ZIP code. Sumner had argued earlier that requiring users to enter a ZIP code before gaining access to the database was "clearly contrary" to the requirement that the database be available to the public.

Responding November 30, Sumner gamely took another stab at getting the League's point across. Part 15 is unambiguous that the information in the database must be publicly accessible approximately 30 days before a BPL system begins operation, he said. Using a ZIP code to gain entry, Sumner continued, "renders the advance notification requirement meaningless to the public" unless someone were to regularly visit the Web site and repeatedly enter a particular ZIP code. But since that practice "is specifically discouraged by the UTC's notice," Sumner pointed out, it's impossible for the public to know about a BPL startup in advance, something the BPL Report and Order seems to require.

As a result, Sumner said, the benefit of a prior notification requirement, while limited as an interference-prevention measure, is lost to BPL operators as well as to licensed radio services that may suffer harmful interference that could have been avoided.

Sumner said the UTC-administered database "provides less than was promised" in the FCC's October 2004 Report and Order. "For advance notification to be meaningful, the public must know when additions and changes to the database occur," he contended. "That is functionally impossible if the 'publicly accessible' database is actually maintained behind an opaque curtain and is only revealed one ZIP code at a time."

One workaround, Sumner suggested, would be to require UTC to make publicly available a list of ZIP codes and the date of the most recent data entry for each. "This also would make it clear when a specific BPL system serves more than one ZIP code area, information that is required by §15.615(a)(3) but that is not available to the public at present except by individual query of each ZIP code."

Sumner said Franca failed to respond to his point regarding the error message that appears when a database user enters a ZIP code where no BPL system apparently has been deployed. At that point, users are asked to provide "written details" about the nature of the interference and the user's licensed operations as well as location--"complete address and coordinates"--operating frequencies, whether mobile or fixed and a brief description of the interference.

"Frankly, UTC has no authority to require the submission of such information from an FCC licensee prior to sharing information that the public is entitled to as a matter of right," Sumner concluded--reiterating a point made in his initial correspondence. "If the database were appropriately accessible the question would never arise."

On November 23, the League told the FCC that the Manassas, Virginia, BPL system was not in compliance with FCC Part 15 rules because its operator failed to provide full information to the public BPL database by the November 19 deadline and the system should be shut down. The letter came barely six weeks after the ARRL called on the FCC to turn off the Manassas BPL system because of unresolved interference complaints to Amateur Radio.

Since the League's letter, a search under ZIP code 20110 indicates the Manassas system has provided a contact name, address, telephone number and e-mail address. Its entry still lacks details about the equipment in use, however.

Source:

The ARRL Letter Vol. 24, No. 47 December 2, 2005

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