What is FCC Docket 03-104 Asking?
from
Merrill L Stevenson, KG6AMW
on
May 25, 2003
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What is FCC Docket 03-104 Asking?
I've been following the responses to this matter on the FCC website. There have been hundreds of responses mostly not in favor of this proposal. What's interesting, most of the responses have been personal opinion with little attention given to what 03-104 is asking. To respond correctly, we have to recognize the FCC is in favor of this matter and they are looking to clear some of the hurdles in the way of this technology so industry can proceed with Broadband over Power Line (BPL) technology. The key here is to specifically address some of the questions they are asking in regards to field-testing, certifications and Part 15 rules interpretation. I highlighted several that might be of interest.
What Are They Asking?
Through this inquiry, we seek information and technical data so that we might evaluate the current state of BPL technology and determine whether changes to Part 15 of the Commission's Rules are necessary to facilitate the deployment of this technology. While BPL may be deployed under our existing Part 15 rules, the rules do not specifically provide measurement procedures that apply to systems using the power line as a transmission medium.
What Is The FCC Saying?
The Commission has observed with great interest and anticipation developments in the area of high-speed communications over power line.
Questions They Want You To Help Us Answer:
I'll start off by naming the chapter in the document, followed by the subsection the question came from. The questions presented here are done so in a abbreviated version to keep this article a reasonable length.
Discussion Chapter From Docket 03-104
Sections 9 through 15 (Statement and Explanation of BPL and Its Benefits)
Section 15 (Questions)
* What spectrum and bandwidth would BPL use?
* Can we share spectrum with In-House BPL?
* What data transmission speeds can BPL achieve?
* What modulation can we use?
* What's the timeline for deployment?
* What standards for measuring conducted emission limits
should we use?
Section 17 (Questions)
* In-House BPL systems built to the HomePlug standard specifications operate in the frequency range from 4.5 to 21 MHz. Are other In-House BPL devices being designed to operate in other portions of the spectrum, and at what bandwidth?
* What is the highest data transmission speed that In-House BPL systems can achieve? What speeds can be typically sustained under normal user environment conditions?
* What are the modulation techniques? What techniques are used for ensuring the security of data, especially when several residential units share the same common distribution transformer? What schemes are used for contention resolution between various In-House BPL devices, if more than one device needs to take control of the electric wire at the same time to communicate?
* Would products developed according to one standard work with products developed according to another standard, without the need for additional equipment, such as converters and adaptors?
* What standards work has been done domestically and internationally on In-House BPL technology and what are the results of such activities? Are there on-going international standards activities that would benefit U.S. industry and what steps should the Commission take to encourage this work?
Section 20 (Questions)
* Can we bypass the power line transformers and would this cause more interference?
* What type of antennas can we use, RF voltage between power line and ground, RF voltage applied differentially between two phases of a power line or use a single power line as a dipole?
* Is there a need to define frequency band that must be avoided in order to protect the licensed users on the same frequencies as those used by BPL?
* Since BPL equipment is installed neighborhood power lines, should our equipment be treated licensed transmitters?
* How would close proximity of BPL equipment to cable TV and other telecommunications located on the same pole affect them?
* What can we do to prevent interference to DSL systems and other cable services?
* What mitigation techniques are used by in house BPL to avoid interference with radio services?
* What are the probable interference environments and propagation patterns of BPL? Are there specific issues of interference that we should address, e.g. an increase in the noise floor?
* Are there test results from field trials of access that may assist in the analysis of harmful interference?
* Are existing Part 15 rules for low speed Carrier current systems adequate to protect authorized users of the spectrum who might be affected by new high speed BPL technology?
* How should the Part 15 rules be tailored both to ensure protection against harmful interference to radio services and to avoid adversely impacting the development and deployment of nascent technology?
* Given their different operating environment is it necessary to tailor rules to differentiate equipment used in Access BPL and In-House BPL applications?
* Is there a need to specify different limits for Access and In-House systems?
* Should Part 15 rules specify both radiated emission limits and conducted emission limits for BPL systems or would one type of limit be sufficient to control interference form both low and high speed BPL?
Section 21 (Want Comments)
We seek comments on measurement methods for all types of carrier current systems including new high-speed Access and In-House BPL devices.
Section 22 (A Statement)
Rather than requiring compliance with measurements for each individual carrier current system installation, we have allowed measurements of radiated emission at three installations that the operator deems as representative of typical installations.
Sections 23 (Questions)
Radiated emissions measurements of carrier current equipment at frequencies below 30 MHz can be time consuming because each installation is unique.
* How should measurement procedures for existing low speed carrier current systems be developed? Can measurement be done in a laboratory or open test site?
* How should measurement procedures for testing new BPL system be developed to promote consistency with measurements of existing carrier current systems?
* If conducted emission limits alone are sufficient to control harmful interference from BPL systems, how should the measurement procedure be specified?
* Existing information is insufficient on the degree of difference in radiated emissions from In-House PLC signals are injected in common mode versus differential mode. Is there data available that shows radiated emission levels from house and buildings located in the US for both?
* How should In-House BPL systems be tested for compliance given they use the buildings wiring as an antenna?
* How should Access BPL system be tested for compliance, given they generally operate in an environment where signals travel on overheard medium voltage lines?
* Are there any international standards that should be investigated for possible adoption to facilitate BPL products for international use?
Section 24 (Statement)
With regards to Section 302 Communications Act of 1934, the FCC carries out its responsibility by establishing technical regulations for transmitters and other equipment. The authorization requires the equipment be tested by the manufacturer or an independent laboratory to demonstrate its compliance. The procedure to which the device is subject depends on the risk of interference the equipment poses to licensed radio services.
Section 25 (Statement)
Certification is an equipment authorization issued by the Commission (FCC) or its designated entities based on representations and test data submitted by the applicant.
Section 26 (Questions)
* Would the new high Access and In-House BPL equipment pose a higher risk of interference to licensed radio services than traditional carrier current systems?
* What components of Access BPL system should be subject to equipment authorizations?
* Should the new Access and In-House BPL equipment be required to comply with either Certification procedure or the Declaration of Conformity under our equipment authorization program?
Section 27 (Statement)
Existing Part 15 rules address power carrier current systems. Existing systems are not subject to the authorization program.
Section 28 (Questions)
* Will existing low power carrier current systems used by utilities be replaced with new high speed BPL equipment?
* Would utilities deploy these new systems and could they exist with older control systems?
* Should power line carrier systems using BPL technology be subject to coordination process the current database maintained by UTC?
* Are any changes needed in the regulations governing power line carrier systems?
* What interference issues if besides the issues raised under the general BPL interference section be addressed with the deployment of high-speed power line carrier systems?
These are the questions in abbreviated form. Once again, read Docket 03-104
for further details.
What Next?
Pick out those questions that are of interest. Answer the question and back it with specific references. There are a number of useful websites to refer to regarding BPL. The most useful is the ARRL (
http://www.arrl.org/tis/info/HTML/plc/ ARRL Main Page For PLC). Other websites include:
http://www.jarl.or.jp/ Japanese Amateur Radio League
http://www.darc.de Germany Deutscher Amateur-Radio-Club (DARC)
http://www.rsgb.org/ Great Britain Radio Society of Great Britain (RSGB)
http://www.veron.nl/maine.htm Society for Amateur Radio in The Netherlands
This article has expired. No more comments may be added.
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What is FCC Docket 03-104 Asking?
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by CASPER669 on May 25, 2003
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It would appear to me that they have more questions than answers. This gives off the impression of jumping into a pool of unknown. With so many unanswered questions, why start investing so many resources into the infrastucture without having at least half of them answered? More than likely, the answer would lie in politics. With electricity being run and owned by companies who basically have a monopoly in their sector, I can see millions of dollars changing hands before it is approved. Especially those of us who live in NY, we all fall victim to the brutalatiy and torture of Con Edison. Although there emergency services are fairly prompt in response time, their lack of basic maintenance for over-head and underground power lines leads one to wonder just how well this new technology would be designed, implemented and maintained. In other states across the nation, I'm sure that communities (more than likely, anyway) receive much better service for their money - and rightfully so. But, it would seem that this new technology - especially one with so many unanswered questions - would make it seem that they are 'filling their eyes before their stomachs'. The fact that there are so many unanswered questions would lead one to believe that they will not move forward until they have met with answers. However, based on what I've read, that doesn't appear to be the case. It's a money-maker. A way to leverage more money from the consumer - whether you subscribe to BPL or not, they will make you, the consumer, pay for it. They'll claim it's to cover the cost of upgrading. Was the upgrade something we asked for, or the power companies?As a LAN Administrator, I'm more than happy to help in the efforts of increasing the availability of Internet access. However, if I were to go to the President of my company with a plan consisting of so many important technical questions that I did not have any answer to, I would be laughed out of his office. Well, the difference here is that the President/Chairman of the Board/whoever is making the decision to design and implement without doing any kind of testing or research that is necessary before you can make this kind of decision. The only reason I can come up with as to why all the questions without answers - and yet they're moving forward with it is because they wish to fill their coffers, no matter what the cost to the consumer. We will be victims of this. At least, that's how I see it. Thank you for taking the time to read my 2 cents and 73!
Chris KC2KFW
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What is FCC Docket 03-104 Asking?
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Anonymous post on May 25, 2003
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The fcc is a joke. They are lap dogs for congress and those in congress get their pac money from industry who want something in return. This is a good example of influence bought. The fcc would have no reason to come up with this issue on their own. Another example of how the government is bought and paid for by industry.
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RE: What is FCC Docket 03-104 Asking?
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by AA4PB on May 25, 2003
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I think the FCC's Docket is far too pre-mature. There has not been enough testing done in order to provide the answers they seek. Common sense tells me that if you put RF in the HF range on open transmission lines, it will be radiated and have the potential to cause interferrence to existing communications. The problem is that I don't have any data to back that up. It seems to me that the FCC needs to pick a poplulated area, put on a test signal for a few months and then get input from hams and other HF users in the area regarding the levels of interferrence experienced.
The other issue is long term maintenance. We already have a nearly constant battle to get the power companies to maintains their lines so that they are not generating RFI from arcing insulators, etc. Some years ago I had a terrible power line RFI problem (over S9) and traced it to a loose bug (connection) on an abandoned 2-foot piece of wire almost a mile away, blowing in the wind. The point is that it doesn't take much to generate terrible RFI that can be distributed a long way on a power line. I wonder how much RFI like that will affect their proposed signals.
When I was experimenting with LORAN for vehicle location it was common to experience problems from the 100 kHz control signals used on some power lines any time you came near these lines. I wonder if any of the LORAN mfgs have any data recorded concerning this as it would appear to be a similar problem.
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RE: What is FCC Docket 03-104 Asking?
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by KB3IMY on May 25, 2003
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Pennsylvania Power & Light compnay is currently testing BPL in or near Allentown Pennsylvania. There was an artical in the Morning Call newspaper ( mcall.com ) describing the test.
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RE: What is FCC Docket 03-104 Asking?
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by AC0X on May 25, 2003
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Do you have a link to the article in the Morning Call? I looked on mcall.com but couldn't find it.
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What is FCC Docket 03-104 Asking?
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by AJ5TT on May 25, 2003
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In Summary, all you experts I read about in this forum, need to comment/respond to this FCC.
Comments below are from another HAM friend who feels very strong that we need to comment. I am preparing my response.. you also need to respond.
Commission wants to know YOUR ideas on BPL, and in particular what you think (or know) about the effects of BPL on licensed services (such as amateur radio).
So far, there are 415 comments in all. Over 300,000 hams in the US have HF privileges, which will be destroyed by BPL/PLC.
It is VERY important that you comment on this FCC proceeding. So far, only about 400 people have filed comments. That represents less than 1/10 of 1 percent of the licensed amateurs in the US.
More information on PLC can be found at:
http://www.arrl.org/tis/info/HTML/plc/
The complete NOI is now available on the FCC Web site.
The FCC now is accepting electronically filed comments via its Electronic Comment Filing System ECFS Express page. This can be accessed via: http://www.fcc.gov/cgb/ecfs/. Specifically, http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi Then type 03-104 on line 1.
The deadline for electronic comments is coming soon (45 days after publication in the Federal Register). The NOI is dated 23 April: Early June will be the last time you can comment.
73,
John - AJ5TT
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RE: What is FCC Docket 03-104 Asking?
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by CASPER669 on May 25, 2003
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FYI... I've sent several comments to the FCC regarding my concerns - not just as a HAM, but also as a possibly victimized consumer. I spoke more often then not on the Amatuer Radio side, though. Thanks for the read!
Chris KC2KFW
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What is FCC Docket 03-104 Asking?
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by AF4O on May 25, 2003
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I agree with AA4PB. I have read the ARRL information and I have a strong belief that this will cause considerable RFI to existing services.
I also agree that, there needs to be a test city done to evaluate this system. I agree with the line maintenance issue. Been there, done that here. After 18 months of dealing with the local util, finally enjoying pwr line rfi free hf/ vhf reception.
My comment has been filed with the FCC and I stand by it.
Chuck
AF4O
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What is FCC Docket 03-104 Asking?
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by AB5XZ on May 25, 2003
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Thanks to KG6AMW for taking the time to distill the NOI for this discussion. I hope it will help.
I have already filed my comments on the NOI, but I have been doing some further background reading and I am really concerned by what I read. Here's why:
FCC Chairman Powell is beating a drum about "interference temperature", which is a vague concept proposed by Dr. Paul Kolodzy of DARPA, FCC, and Stevens Institute of Technology, among other well-known organizations.
"Interference Temperature" is, as I read the concept, the sum of natural noise and man-made noise. Dr. Kolodzy doesn't say how this would be measured. He does say that a thorough survey of the regulated spectrum is necessary. Presumably it would be measured at the receiver. Presumably it would be used, band-by-band, to regulate the amount of interference that a band's users would be able to inject into it. Chairman Powell misunderstands this concept so much that he introduced "interference temperature" into his discussion of this NOI. There are several hundred groups of licensed users in the 1.8-80MHz spectrum. Each group has one or more bands to use. It is patently ridiculous ("egregious" might be clearer to the legal folks) to try to apply "noise temperature" to all of these groups. Meanwhile, Dr. Kolodzy has not done anything to counter the misconception; I consider that irresponsible.
In the same sworn testimony, Dr. Kolodzy states, without a shred of supporting evidence, that "Digital signals are inherently more robust and resistant to interference than analog signals. Moreover, digital signal processing techniques, such as coding and error correction, are more effective at rejecting interfering signals. Thus, spectrum policies can and should reflect this increased ability to tolerate interference." These are stated as facts. The first one "inherently more robust and resistant to interference" is simply not true. The second one "DSP more effective" is incomplete, because it doesn't say what digital techniques are "more effective" than, and it's a necessary condition for the first statement to be true. The third statement does not logically follow from the first two. In other words, Dr. Kolodzy is blowing smoke at the Senate of the United States. Presumably, he has blown the same smoke at the FCC, who is taking it all in. This stuff reads like the Radio Shack ads that want to sell me "digital-ready" stereo headphones! If you really want to test "digital is inherently more robust than analog", take your favorite DVD and your favorite VHS tape, and scratch them both with a safety pin. Now see which one still plays.
I apologize (sort of) for putting all this not-too-closely-related comment in this thread. The point I would like to make is that the FCC is pursuing an agenda that will make a shambles of telecommunications, starting with all of HF. Too bad.
73
Tom O'Brien
AB5XZ
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RE: What is FCC Docket 03-104 Asking?
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by KB3IMY on May 25, 2003
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The article is on the mcall.com web site in their archives. Locate the archives link near the bottom of the page on the left. Search for broadband power line . They want $2. for it. You can view an small portion of it free.
I have added a copy on my web site at http://www.ehunsberger.com/html/bpl_allentown__pa.html . There is a part of the article missing that I believe describes the location of the test more precise. I will keep the copy on my web site for a short time.
Mike
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RE: What is FCC Docket 03-104 Asking?
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by KE4IZA on May 26, 2003
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I agree with WA8KJP. The FCC is nothing but a lap dog for those in congress. Amateur radio does not stand a chance when it comes to multiBillion dollar deals. When it comes right down to it, I fear our frequency allocations would be sold of to the highest bidder. It has already been suggested amateur radio serves no furthur purpose and their are firms willing to pay BIG $$$ for our frequencies. There are already those in governement positions who see amateur radio as a fallen tree in the road to progress and that tree needs to be pushed aside. I just made general class so I hope amateur radio survives but I really do expect the governmental baracudas to starts drueling over our allocations.
73's
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RE: What is FCC Docket 03-104 Asking?
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by K0BG on May 26, 2003
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I take note that Casper669 used the phrase "...lie in politics." And this is exactly what we're up against.
I think we should ask our fellow amateurs in Japan what they think about BPL.
As for me, I have but one question: Did Al Gore invent this too?
Alan, KØBG
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RE: What is FCC Docket 03-104 Asking?
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by AB5XZ on May 26, 2003
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Lap dog or not, the FCC is going to do something with the regulations. Please file your comment on this docket and let them know your opinion and your ideas. They may not listen to you alone, but they *will* listen to 600,000 of us.
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What is FCC Docket 03-104 Asking?
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by KG6AMW on May 26, 2003
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That's correct we are in a battle we may lose. However, its better to die while fighting for something you believe in than sitting around bemoaning our condition and fact that politicians are scallywags. History is full of poor business ethics and government go alongs. This is life. But you don't have sit by and watch it without acting. Now is the time to get on record with your comments.
KG6AMW
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What is FCC Docket 03-104 Asking?
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by W2VD on May 26, 2003
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How about some freebies if you can "help us out," dear FCC...
http://www.newsmax.com/archives/articles/2003/5/25/121501.shtml
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What is FCC Docket 03-104 Asking?
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by W8OB on May 26, 2003
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It would be nice to be able to access the comment site. Although I was one of the first to file a comment here the past several days I have not been able to get past the opening page to view any new comments. Maybe this is just the way to slow down all the neg comments being received. The rest of you guys better get your heads out of the sand and other places and file comments on this White Elephant. If this comes about you can pretty much kiss hf and a large portion of VHF goodbye( Take note of this you techs who feel this will not affect you). With only .1 of 1 percent of the licensed hams having filed commments so far This is a for sure thing. Hey anybody on here from Allentown, Pa where they have been running some BPL tests would like to hear from you as well.
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What is FCC Docket 03-104 Asking?
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by N3NL on May 26, 2003
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Comment due dates for this docket.
FEDERAL COMMUNICATIONS COMMISSION
47 CFR Part 15
[ET Docket No. 03-104; FCC 03-100]
Broadband Power Line Systems
AGENCY: Federal Communications Commission.
ACTION: Proposed rule; notice of inquiry.
-----------------------------------------------------------------------
SUMMARY: This document requests comment from the public on the current
state of Broadband Power Line (BPL) technology and to determine whether
changes to the Commission's rules are necessary to facilitate the
deployment of this technology. The Commission believes that BPL could
play an important role in providing additional competition in the
offering of broadband infrastructure to the American home and consumers
because power lines reach virtually every community in the country.
DATES: Written comments are due on or before August 6, 2003, and reply
comments are due on or before September 5, 2003.
ADDRESSES: Office of the Secretary, Federal Communications Commission,
445 12th Street, SW., Washington, DC 20554. See supplementary
information for filing instructions.
FOR FURTHER INFORMATION CONTACT: Anh T. Wride, Office of Engineering
and Technology, (202) 418-0577, TTY (202) 418-2989, e-mail:
anh.wride@fcc.gov.
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RE: What is FCC Docket 03-104 Asking?
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by KG6AMW on May 26, 2003
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W8OB is correct, there is a problem here. Here's another way in. When you get to the main FCC Electronic Comment Filing System (ECFS) website check out the menu on the left, follow it down and check on alternate link which then gives you access.
KG6AMW
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What is FCC Docket 03-104 Asking?
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by WA8QNN on May 26, 2003
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Good article and many excellent replies. One question that that has been touched on only briefly. Won't an amateur HF transmitter cause interference with BPL broadcasting? This ultimately could be our ace in the hole. House Bill HR713 and Senate Bill S537 are currently in committee. These could also help our cause.
Larry
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RE: What is FCC Docket 03-104 Asking?
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by AB5XZ on May 27, 2003
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Thanks to N3NL for getting the comment deadlines!
Now I have some questions:
1. N3NL, where did you find the information? Presumably on the FCC web site, but precisely where?
2. Everybody, what is the procedure for filing reply comments? I haven't filed a reply comment before, and I want to be prepared.
73TomAB5XZ
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RE: What is FCC Docket 03-104 Asking?
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by KE4MOB on May 27, 2003
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***MAKE YOUR VOICE HEARD---FILE A COMMENT***
The NOI is now available on the FCC Web site. The FCC now is accepting electronically filed comments via its Electronic Comment Filing System. Just go to:
http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
Then type 03-104 on line 1.
Select the "Name" field on line 2.
Your name goes on line 3.
Your mailing address goes on lines 7 through 10.
Select "Comment" on line 12. Then scroll down to the bottom of the page and type your comment in the large box (or if you wish you can upload a file in Word format) and hit "Submit". That's it!
73 to all,
Steve Matda, KE4MOB
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RE: What is FCC Docket 03-104 Asking?
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by AB5XZ on May 27, 2003
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Answer to Part 1 of my own question:
"How do I find the Federal Register publication of the NOI in FCC Docket 03-104?"
Go to
http://www.gpoaccess.gov/fr/index.html
Select the option to search the current volume (2003) of the Federal Register.
Then search for "Broadband Power Line", which will get you a PDF of the actual pages of the Federal Register (28182 through 28186), containing the Notice of Inquiry and the deadlines for filing comments.
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RE: What is FCC Docket 03-104 Asking?
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by AB5XZ on May 27, 2003
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NOTICE: There's some fine print in the Notice of Inquiry:
"Generally, only one copy of an electronic submission must be filed. If multiple docket or rulemaking numbers appear in the caption of this proceeding, however, commenters must transmit one electronic copy of the comments to each docket or rulemaking number referenced in the caption."
I read this to mean that I need to go back and get my comment to Docket 03-104 and file it again to Docket 03-100. Ugh.
Somebody tell me I'm wrong!
73TomAB5XZ
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RE: What is FCC Docket 03-104 Asking?
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by AB5XZ on May 27, 2003
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According to Ed Hare W1RFI, at ARRL HQ, the 03-104 docket number is the only one that comments need to be filed against.
73TomAB5XZ
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What is FCC Docket 03-104 Asking?
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by N4DFP on May 28, 2003
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I think I will file a comment on this, though I never have done so before. I used to be an over the road truck driver. I could drive for miles with incessant buzz from leaky power lines. If the power companies are unwilling or unable to correct problems with their existing service, why should they be permitted to operate another service which by its nature will cause interference, AND be interfefed with by their current service?
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What is FCC Docket 03-104 Asking?
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by AB5XZ on May 29, 2003
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I've seen several instances of the same comment being filed multiple (10+) times by the same person. That's not going to help; this is NOT like voting for our favorite player(s) for the All-Star game.
Please urge your ham friends to read the NOI, then prepare and file their comments. Offer to help them file, if they have problems with the filing system.
73TomAB5XZ
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What is FCC Docket 03-104 Asking?
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by W8OB on May 31, 2003
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I noticed for the first time in quite awhile the comment site is back on line and you can now once again read the filed comments made. Again to echo anothers already posted comments here, Ladies and Gentlemen please try to refer to more than Ham radio on your comments, simply saying I do not want BPL because I am a ham radio operator is not going to cut it. On another note I see a couple of comments from people who live out in the boonies and think this BPL thing is the greatest happening since sliced bread, This being a free country and all but don't these people realize that living in rural areas does have some disadvantages over city life?. I guess they have never heard of dial up access or satelite access. In the long run if this comes to pass, the powers that be are going to make sure their rear pockets get lined good, plus they are going to need to take in plenty of bread to pay off promise's made along the way. I just can't see BPL as being a inexpensive way for high speed internet.
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RE: What is FCC Docket 03-104 Asking?
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by KG6AMW on May 31, 2003
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I've reviewed many of the responses and have noticed that few Short Wave Listeners have posted comments. Does any know if the SWL organizations are aware of 03-104?
KG6AMW
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What is FCC Docket 03-104 Asking?
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by W8OB on May 31, 2003
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What I am wondering is where are comments from all the radio mgfrs? Where are comments from the couple of dozen organizations and clubs?
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What is FCC Docket 03-104 Asking?
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by AC6YD on June 1, 2003
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Although I understand what the FCC is asking, just who in the amateur community has the ability to respond? I believe gentleman that BPL is a forgone conclusion in that the only people who posses the resources to make a reasonable response to such technical questions are the very people who will derive monetary rewards if the system is approved.
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RE: What is FCC Docket 03-104 Asking?
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by AB5XZ on June 2, 2003
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To AC6YD's question "Who in the amateur community has the ability to respond?"
The ARRL is probably the only voice we (in the USA) have. Ed Hare, W1RFI, has built a huge base of information on the topic, and has worked with the HomePlug group (the in-house BPL) to develop a standard that's not destructive to ham radio. As I understand it, ARRL has also contacted the manufacturers and users of the Access BPL systems to provide ham radio input.
There are also hams who work for the BPL/PLC manufacturers and the power companies, but I don't expect them to champion ham radio in the face of a conflict of interest.
In Japan, the JARL has done a superb job of getting involved in the tests and providing input.
73TomAB5XZ
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What is FCC Docket 03-104 Asking?
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by KG6AMW on June 2, 2003
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I also feel this whole matter is pretty well decided, the only thing left has to do with Part 15 rules being modified to let this thing fly. I know some of hams out there have strong technical backgrounds and excellent writing skills, but have yet to comment. Where are you?
KG6AMW
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What is FCC Docket 03-104 Asking?
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by W8OB on June 2, 2003
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Hey any legal eagles out here? Could not this so called wonder system with its potential to wipe out all communications from 2-80mhz be somehow infringing on our rights to be able to hear many different sides of the same story via shortwave radio and other mediums? Is this not a proposal to allow legal jamming? Whoa I am starting to sound like a paranoid libber here but just wondering
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RE: What is FCC Docket 03-104 Asking?
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by KO6OR on June 2, 2003
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Tom
"In the same sworn testimony, Dr. Kolodzy states, without a shred of supporting evidence, that "Digital signals are inherently more robust and resistant to interference than analog signals. Moreover, digital signal processing techniques, such as coding and error correction, are more effective at rejecting interfering signals. Thus, spectrum policies can and should reflect this increased ability to tolerate interference." These are stated as facts. The first one "inherently more robust and resistant to interference" is simply not true. The second one "DSP more effective" is incomplete, because it doesn't say what digital techniques are "more effective" than, and it's a necessary condition for the first statement to be true."
I don't know that I fully understand your issues and certainly haven't read the source testimony, but I have to say that as a general engineering principle digital signals are more robust and less subject to interference than analog ones, and that there are many coding and error correction schemes that allow recovery of data; therefore digital signals might not need the same amount of protection from interference. It is true, at least in general, and I'm puzzled by your statement that it is not. The data recovery/coding/error correction techniques used for digital data are more effective than any schemes for analog data protection.
As for your "scratch it with a pin" test -- well, I submit that has nothing to do with the point stated. First, it's an interference with the media, not the signal; second CD's could be designed to be resistant to that kind of "interference" (this isn't interference as I understand the term technically, though) and have dual encoding schemes or error correction schemes -- they simply have not been designed against this specific hazard. On the other hand an analog signal is much easier to degrade than a digital one.
I'm not spoiling for a fight, but I don't understand your statements in opposition.
The basic principles, whether they are correctly applied to the issue before the FCC, whether they are relevant, whether they are being used in context, are nevertheless characteristic of digital and analog signal systems. I've taught those basic principles in some college level engineering courses. Digital signals are more resistant to corruption, and specific schemes for data protection, correction, recovery are legion.
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RE: What is FCC Docket 03-104 Asking?
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by W1RFI on June 2, 2003
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From AC6YD on June 1, 2003:
> Although I understand what the FCC is asking, just
> who in the amateur community has the ability to
> respond? I believe gentleman that BPL is a forgone
> conclusion in that the only people who posses the
> resources to make a reasonable response to such
> technical questions are the very people who will
> derive monetary rewards if the system is approved.
Actually, many of those folks don't have the expertise to make a reasonable response, either. I recently had to explain to one manufacturer why he can't tie the output of two signal generators in parallel to make IMD measurements. I told another why making field-strength measurements with an antenna 1.5 meters off the ground was not finding the peak field near a power-line radiator. The majority of RF engineers I speak with truly believed that the Part 15 emissions limits protect against interference to nearby systems, until I run the math that shows that a 30 uV/m field will give an S9+ level signal to typical ham antennas.
73,
Ed Hare, W1RFI
ARRL Lab
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RE: What is FCC Docket 03-104 Asking?
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by AB5XZ on June 2, 2003
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Phil,
My issue with Dr. Kolodzy's testimony is, fundamentally, with his use of the word "inherently", which I take to mean "by their nature".
Shannon's law does not distinguish between analog and digital signals when describing the effect of noise on channel capacity. I grant that there are many robust methods of encoding information to protect it against noise in the channel. Even so, every digital signal is encoded as an analog signal (i.e., a voltage or a current). The processing is what makes the difference, in my mind. Processing can be analog or digital. Today's digital signal processing does amazing things that are well beyond what can be done with analog processing (e.g. active filters).
As far as my "safety pin" analogy, I was intending for the scratch to be treated as interference with the channel (which includes the media). Maybe it was a bad example to use for an analogy. Even so, the Spectrum Policy Task Force uses a similar comparison when it talks about impairment of digital TV vs. analog TV signals. Roughly, "Analog TV signals degrade gradually, and digital TV signals are *lost* at some discrete point (e.g., when the error correction method fails)." (Spectrum Efficiency Working Group Final Report, page 26.)
Anyway, what annoyed me about the testimony was that as I read more, it began to sound like the stereo salesman who pitches me a headset that's "digital ready", without understanding that the headset is an analog device.
Thanks for your thoughtful comments.
73TomAB5XZ
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RE: What is FCC Docket 03-104 Asking?
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by W1RFI on June 4, 2003
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> Shannon's law does not distinguish between analog
> and digital signals when describing the effect of
> noise on channel capacity. I grant that there are
> many robust methods of encoding information to
> protect it against noise in the channel.
The problem is that many analog systems do not come close to the Shannon limit, so noise has much more of an effect than it needs to. Digital modulation usually comes closer.
Those robust methods do exist. At what cost? And, if they provide immunity to noise, that immunity would simply mean that communication could happen at lower power levels than it could with analog systems, or at greater range for the same amount of power. Using the improved capability as an excuse to allow more noise is, IMHO, wasteful.
HF is not the place to be discussing "interference temperature." The vagracies of propagation often mean that signals that are loud one day are being scratched out of the noise the next. Every dB of noise means less communications capabibility, or communications capabibility less of the time.
Even on VHF and above, one needs to be incredibly careful in permitting noise. It can apply to point-to-point links, where noise margin can be built in to the system design (translate: use more power than you would need if there were no noise), with permitted low power operation happening locally in nearby areas. But when one gets near those noise sources, they can be incredibly loud.
The ones promoting "noise temperature" are the ones that want access to spectrum they currently can't use. The ones that will object are the ones whose communications capabilities will be diminished by that noise or whose systems need to use more power to accomplish their desired communications.
Spread spectrum promised us a free lunch. It was not. Ultrawideband promised us a free lunch. It will not be. Noise temperature promises a free lunch, too, but the bottom line is that noise and power and communications range are all related in known ways, and if you change one factor, the others must be adjusted to compensate.
There are good reasons to use those robust modulation schemes, but allowing more noise on the same frequency should not be one of them.
73,
Ed Hare, W1RFI
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What is FCC Docket 03-104 Asking?
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by N3NL on June 4, 2003
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Hello Ed (W1RFI),
Thank you for your excellent continuing comments
on the subject of BPL. Please place this material
on the ARRL web site home page as well. This would
assist other hams in their comments to the FCC on this
subject.
Keep up the good work.
73, Nickolaus E. Leggett, N3NL
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What is FCC Docket 03-104 Asking?
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by KA1KI on June 4, 2003
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Let me see if I get this right. We have industry propogating HF signals down an efficient long wire antenna, that when modled in NEC produces at least 11 dbd free-space gain at points on termination (transformers and abrupt angles along the power line). The industry is claiming it meets FCC part 15 requirements by measuring fiels strength at the nulls off to the side of the antenna. The FCC is contemplating rule changes to "facilitate" PLC. Which, I suspect. will allow such devices to radiate as much power as they can, as long as present levels are not exceeded at the 90 degree null in the antenna(s) of the Part 15 devices. And we are asking what the question is?
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RE: What is FCC Docket 03-104 Asking?
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by KG6AMW on June 4, 2003
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We have approximately 630 comments as of 04/June/2003. The FCC will take comments up to 15/June/2003. Now is the time to get on record with the FCC with your comments.
KG6AMW
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RE: What is FCC Docket 03-104 Asking?
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by AA3IG on June 5, 2003
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This is the time, now more than ever, when amateur radio operators must ban together, for the good of our most precious hobby. I urge everyone to become familiar with FCC Docket 03-104 , BPL/PLC. Then make your voices heard by filing your comments to the FCC.
It is your right, your opinion, your hobby at stake.
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649 as of 6/5/03
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by AA3M on June 5, 2003
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I realize not all HAMS have internet access. If you're reading this, then PLEASE comment. It doesn't need to be real long, or real technical. I read several comments ( about 50 ) and I got the theme pretty quick. But you should take the five minutes to let them (FCC) know where you are on this. Won't cost you postage, hassle of finding the address and walking to the mailbox. Five minutes
I'll walk you through it.
1.
goto http://gullfoss2.fcc.gov/ecfs/Upload
Just copy the url into your browser and make the selection when you get there. (It was the top one when I last visited )
2.
To select, you click the button for the
"Broadband Over Power Line (BPL) - Docket 03-104"
and hit the continue button at the bottom of the selections.
3.
Fill out the form, put your "comments" in the window provided.
I am not positive on the cut-off date for comments so.... NOW is a good time.
This IS a public forum so remember anything you post will be open to the public.
Thanks
Good Luck and 73's
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What is FCC Docket 03-104 Asking?
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by W8OB on June 7, 2003
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Again for you guys that for whatever reason have not filed comments on this. Between this proposal and Presidents Bush's order yesterday to study frequency use, you better read between the lines and get busy on this one.
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What is FCC Docket 03-104 Asking?
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by N3NL on June 7, 2003
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New shorter comment deadline for BPL docket. News
from the ARRL:
FCC corrects comment, reply comment dates in Broadband over Power Line proceeding: The FCC says comment and reply comment deadlines in its Broadband over Power Line (BPL) Notice of Inquiry (ET Docket 03-104) published May 23 in the Federal Register were incorrect. In a correction issued June 3, the FCC announced that comments from the public in this proceeding are due on or before July 7, 2003. Reply comments are due on or before August 6, 2003.
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