ARRL Urges Informed Comments in FCC BPL Inquiry:

The ARRL is urging amateurs to file well-thought-out, informed comments when responding to the FCC's Broadband Over Power Line (BPL) Notice of Inquiry (ET Docket 03-104). The FCC published its NOI on May 23. The NOI asks how the FCC should regulate the delivery of broadband services to homes and businesses using electrical wiring to conduct high-speed digital signals. While the FCC has dubbed this technology Broadband over Power Line, it's more commonly known as Power Line Carrier or PLC.

BPL would use building and/or overhead power lines to conduct HF and low-VHF digital signals to network computers. The FCC has expressed its unabashed enthusiasm for BPL, which it views as a competitive Internet access point. Utilities consider BPL as another means to use existing infrastructure to generate additional revenue.

The NOI is not asking if BPL technology should be permitted. Under existing FCC rules, BPL systems may be built and used in the US right now. The FCC is asking how the rules might be changed "to promote and encourage new BPL technology," in the words of the NOI.

Present FCC Part 15 rules say that carrier-current systems--including BPL/PLC--need to meet the general radiated emission limits for unlicensed "intentional emitters." While the rules permit BPL at significant power levels, utilities would prefer that the FCC authorize even higher power levels. BPL systems under development and in field trials use spectrum between 1.7 and 80 MHz, but the NOI also asks whether BPL should operate on other parts of the spectrum as well.

As of mid-June, nearly 1000 comments already had been filed in the proceeding. The ARRL has urged amateurs who comment to outline the important uses they make of Amateur Radio and the impact strong interference from BPL could have at HF and low-VHF amateur frequencies.

Electric utility companies will operate many, if not most, BPL systems. ARRL members who have had experience dealing with power line interference and utilities' responses to complaints also may want to describe those experiences in their comments to the Commission.

Amateurs filing comments to the FCC NOI might want to consider these topics and points:

* Amateur Radio is a valuable resource that must be protected.

* Describe the uses you make of Amateur Radio, especially those with a public service or emergency communication aspect.

* The present FCC Part 15 limits for this technology already can result in substantial interference potential to amateur frequencies.

* BPL systems that radiate on wide swaths of spectrum and occupy entire neighborhoods have greater interference potential than localized systems, such as switching power supplies or electric motors.

* The FCC has promised to protect licensed users of the spectrum. We must hold them to that promise.

For more information, see "Understanding the FCC's Broadband Over Power Line (BPL) Notice of Inquiry" http://www.arrl.org/news/features/2003/06/19/2/. An ARRL white paper, "Calculated Impact of PLC on Stations Operating in the Amateur Radio Service" http://www.arrl.org/tis/info/HTML/plc/files/C63NovPLC.pdf provides technical details. The ARRL's Broadband Over Power Line resource page contains links to worldwide studies and other resources.

The ARRL has initiated an important Spectrum Defense Fund campaign to support activities to educate government officials on the potential threat that BPL poses to Amateur Radio. To find out more, or to support ARRL's efforts in this area, visit the ARRL's secure BPL Web site https://www.arrl.org/forms/development/donations/bpl/

The complete NOI is available on the FCC Web site http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-100A1.doc.

Comments are due on or before July 7, 2003. Reply comments are due on or before August 6, 2003. Interested parties may submit electronically filed comments via the FCC's Electronic Comment Filing System (ECFS) http://www.fcc.gov/cgb/ecfs/. Under ECFS Main Links, click on "Submit a Filing." In the "Proceeding" field, enter "03-104" and complete the required field. Comments may be typed into a form or you may attach a file containing your comments. Comments also may be submitted via e-mail, per instructions on the ECFS page.

Source:

The ARRL Letter Vol. 22, No. 25 June 20, 2003

(If the primary ECFS link fails, here a link to the article that will help you to file your comment via the alternate ECFS link. http://www.eham.net/articles/5603 -- ed.)

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