Put BPL Proceeding on Ice for Further Interference Evaluation, ARRL Says:
from
The ARRL Letter, Vol 23, No 19
on
May 8, 2004
Website:
http://www.arrl.org/
View comments about this article!
Put BPL Proceeding on Ice for Further Interference Evaluation, ARRL Says:
The ARRL has asked the FCC to put its BPL proceeding on hold to allow more
thorough research of BPL's interference potential to licensed radio
services. Among other things, the ARRL wants to more closely review the
lengthy National Telecommunications and Information Administration (NTIA)
Part 1 BPL study released April 27. In comments filed May 3 in response to
the FCC's February 23 BPL Notice of Proposed Rule Making (NPRM) in ET
Docket 03-47, the League also called on the FCC to apply "considerably
more conservative radiated emission limits" to BPL than those applying to
"normal" Part 15 devices. Five technical exhibits, including an
ARRL-commissioned independent study at BPL trial areas and additional
research, accompanied the League's comments.
"The Commission cannot be in such a hurry to deploy BPL . . . that it must
sweep under the rug the mounting evidence that BPL is a significant source
of interference to licensed radio services and is not in the public
interest," the ARRL declared.
The League also took the FCC to task for its willingness to balance BPL's
presumed benefits against the potential of harmful interference. "The
principal obligation of the Commission in permitting unlicensed devices or
systems is to establish a radiated emission level that is sufficiently low
that by their operation they will predictably not interfere with licensed
radio services," the ARRL emphasized.
The ARRL told the FCC that applying existing radiated emission limits to
so-called "access BPL" systems is inappropriate. "Those levels are far too
high and were designed to address the interference of point-source
radiators," the League said. "It is obvious that access BPL systems are
distributive, line-source radiators" and the FCC should apply a limit low
enough to prevent interference to mobile stations that might operate in
BPL-served neighborhoods. The ARRL suggested that 0 dBuV/m at the antenna
measured at 10 meters (approximately 33 feet) from the power line would be
an "acceptable" radiated emission level.
The League further proposed amending Part 15 rules (§15.109) to require
BPL systems to incorporate adaptive interference resolution techniques
adequate to cause them to cease operation within an hour following a
report of harmful interference to an FCC licensee's station. The BPL
system then couldn't resume operation within one kilometer (approximately
0.62 mile) of the complainant's station "unless and until the harmful
interference is resolved." The ARRL also would require BPL systems to
supply detailed information on their systems to a public Web-based
database.
The FCC's NPRM offers no support for its conclusion that interference to
licensed services would be minimal, the ARRL said, and it noted that
amateur licensees have filed more than two dozen BPL interference
complaints with the FCC.
"Some of these interference problems have persisted, notwithstanding the
good faith efforts of some BPL service providers to resolve the problems,"
the ARRL noted. "In other cases, the complaints are simply ignored. None
has been adjudicated by the Commission, as far as the ARRL can tell."
Instead, the League said, amateurs' BPL complaints "remain under wraps" in
the Office of Engineering and Technology instead of being handled by the
FCC's Enforcement Bureau, which typically deals with power line noise
complaints from radio amateurs.
"Mere mitigation" of interference is not sufficient, the ARRL said. "It is
the absolute obligation of the operator of a Part 15 device or system to
prevent interference." The League pointed out that the FCC's NPRM does not
require interference resolution. "The interference to fixed amateur
stations located in residences in normal geographic proximity to overhead
power lines will be devastating and will preclude Amateur Radio
communications," the League predicted. It called the FCC's proposed
mitigation techniques "too little, too late to avoid widespread
interference."
Referring to its main BPL study, the League said measurements at one site
within a BPL test system in Emmaus, Pennsylvania, "exceeded FCC Part 15
limits by up to 20 dB or more." At another test site in Whitehall,
Pennsylvania, using another technology, the study concluded that the BPL
signals--while apparently within Part 15 limits--"would have interfered
seriously with reception of Amateur Radio signals."
"This proceeding should be placed on hold for a year in order to work out
appropriate interference avoidance and resolution standards," the League
concluded.
The League was among more than 1000 individuals and entities commenting in
the proceeding by the May 3 deadline. Reply comments are due Tuesday, June
1. On the eve of the comment deadline, the FCC denied several
requests--including one from the ARRL--to extend the comment period.
The League's comments are posted on the ARRL Web site
http://www.arrl.org/announce/regulatory/et04-37/ARRL_04-37_Comments.pdf.
Source:
The ARRL Letter
Vol. 23, No. 19
May 7, 2004
This article has expired. No more comments may be added.
|
Put BPL Proceeding on Ice for Further Interference
|
|
|
by WIRELESS on May 8, 2004
|
Mail this to a friend!
|
|
When is the ARRL going to figure out the FCC isn't listening to them? The only thing that might get the FCC's attention are papers served to them indicating the government is being sued for not inforcing their own rules and regulations applicable to Part 15 interference standards.
|
| |
|
RE: Put BPL Proceeding on Ice for Further Interfer
|
|
|
by K0RFD on May 8, 2004
|
Mail this to a friend!
|
I think the ARRL did a good job with their comments.
Whether the FCC is listening or not doesn't affect whether you should or shouldn't file comments.
Not filing comments is much worse than filing even if no one is listening because it gives the Commissioners the political cover to accept the BPL industry's lies as unchallenged.
The ARRL and thousands of hams who commented during the NOI got this rulemaking to include MORE stringent provisions for BPL than for other Part 15 users, as opposed to the less stringent provisions that the NOI was asking for. We have a way to go yet, but we aren't going to get there if ARRL, NTIA, other spectrum user organizations, and individual users just roll over and play dead.
NEVER, never, never fail to express an opinion when asked. Even though you might lose, you can't win if you don't play.
|
| |
|
RE: Put BPL Proceeding on Ice for Further Interfer
|
|
|
by N0YM on May 8, 2004
|
Mail this to a friend!
|
The FCC may not have a choice. ARRL has seen the writing on the wall. Their latest filing isn't another plea to the FCC; it's notice that they're lining up for legal action on the grounds that the FCC has no statutory authority to authorize something that is likely to interfere with licensed services. Likewise, ARRL contends that the FCC has no right to apply a balancing test between their idea of "public good" and interference potential, where interference to licensed services from unlicensed services is concerned.
From what I can see, they've probably got a pretty strong case.
|
| |
|
RE: Put BPL Proceeding on Ice for Further Interfer
|
|
|
by KE4MOB on May 9, 2004
|
Mail this to a friend!
|
All I've got to say is this:
A) This respose makes me proud to be an ARRL member...W1AW must be smiling right now.
B) Let the games begin!!
|
| |
|
Put BPL Proceeding on Ice for Further Interference
|
|
|
by KD5IR on May 9, 2004
|
Mail this to a friend!
|
............It appears that the ARRL strategy is too respond to each NPRM with verifable data that disproves the assertions of BPL providers that there is "No Interference" . At some point this back and forth will play itself out and the FCC will probably issue a ruling in favor of BPL and at that point is probably where the ARRL will initate Legal Action. By following this strategy a judge can't ask the ARRL to repeat a "Missed step" in the sequence of administrative hearings and thus delay the lawsuit.
...........Hopefully, the judge will put a hold on further BPL startups and then the issue can be resolved on its merits in the Federal Court system which would seem to have alittle more objectivity than the Lobbyists currently posing as FCC regulators. s.kuteman , kd5ir
|
| |
|
RE: Put BPL Proceeding on Ice for Further Interfer
|
|
|
by K4RAF on May 9, 2004
|
Mail this to a friend!
|
BPL = Bonnie Promoting Looniness
Get some new material, will ya...
|
| |
|
RE: Put BPL Proceeding on Ice for Further Interfer
|
|
|
by KQ6XA on May 10, 2004
|
Mail this to a friend!
|
B.P.L. = Bush Power Lobby
To learn why unlicensed BPL will be allowed to take over the world's precious HF bands, we needn't look for a technical explanation. Technology and logical argument mean nothing in this case. To quote an infamous Watergate figure, just "follow the money."
The equivalent radiated signal of a typical BPL system using thousands of small broadband transmitters and the "distributed antenna" of a county electrical grid, is comparable to the coverage of a 10,000Watt AM Broadcast transmitter.
Only one of the most powerful government lobbying groups could have pulled this off: Big Energy.
Such a bold taking of the HF spectrum resource by special interest fat cats is made easy during an administration that is so corrupted by Big Energy money. This is the administration who was ushered into office by a minority of the popular vote in a s'election that was a sham for democracy in the world.
They say "you can't buy a politician".
But it looks like Big Energy got a good deal on a rental.
|
| |
|
Put BPL Proceeding on Ice for Further Interference
|
|
|
by KG6AMW on May 10, 2004
|
Mail this to a friend!
|
I've read quite a bit about this BPL matter and from what I see, the FCC is going to press on and approve it. What's a mystery to me is you have the NTIA and ARRL putting forth extensive technical data demonstrating potential interference problems versus nothing from BPL companies demonstrating the counter and yet the FCC continues to accommodate BPL implementation. The FCC has hurt their creditability not only with us, but also with many in the telecommunications industry. Truly this is an embarrassment to current sitting FCC commissioners who are assigned the responsibility of regulating and protecting a national and worldwide resource and have chosen the route of political expediency for a second rate Internet delivery system that isn’t even telecommunications. It’s also an embarrassment to their engineering office who were taken in by a group of second rate technology companies without demanding hard technical data. What a mess.
KG6AMW
|
| |
|
RE: Put BPL Proceeding on Ice for Further Interfer
|
|
|
by KE4MOB on May 10, 2004
|
Mail this to a friend!
|
I really wish that everything could be explained away by a government conspiracy (it's all Dubya's fault!), but that explanation only works for those who have blinders on and miss the fact that yes, there is life outside the Beltway. Most people outside the beltway (who can look at the big picture) would see that BPL is a result of a confluence of factors. Among those:
A) A regulated public utility industry that is looking for any way possible to make a profit outside of the traditional means.
B) A deregulated telecommunications industry that has failed to become truly market driven and suffering from huge debt loads due to the cell phone buildout.
C) An administration fighting for its life and wanting to show the people by any means possible that, yes, they care.
D) A general move of spectrum users away from shortwave.
Some random observations:
Two test areas was Raleigh, NC and Manassas, VA. Now there's two rural areas if I've ever seen them! Next thing you know, they'll do a *real* rural test and hook up New York City. My guess is that these places already have DSL/Cable/Fiber/Dialup, and BPL is undercutting that. Give it a year for the market to adjust, and BPL won't be the economic panacea everyone is thinking to it be.
And as an aside:
I'd bet Al Gore would have loved BPL...after all didn't he invent the internet?
|
| |
|
RE: Put BPL Proceeding on Ice for Further Interfer
|
|
|
by NE1Z on May 11, 2004
|
Mail this to a friend!
|
I love reading ignorant conspiracy theories from dopey people who can't even understand the electoral college & how it works... but they know who does what?
Then again, those same people use affirmative action as a crowd shield to hide behind in an attempt to escape the challenge from the intellectually armed!
|
| |
|
RE: Put BPL Proceeding on Ice for Further Interfer
|
|
|
by W1RFI on May 11, 2004
|
Mail this to a friend!
|
Here is what the National Rural Telecommunications Cooperative and the National Rural Electric Cooperatives Associationhad to say about BPL in their filings:
"As not- for-profit organizations representing hundreds of rural entities providing a full range of telecommunications services to rural America, NRTC and NRECA support the Commission’s approach to the deployment of Access broadband over power line(“BPL”) as another promising technology to bring broadband to consumers. We also urge the Commission to continue to exercise prudent caution in its approach to protecting licensed spectrum users from harmful interference while encouraging exploration of BPL technology. Specifically, the Commission should refrain from relaxing Part 15 of its rules, or establishing new rules until it is determined with reasonable certainty that interference can be limited to acceptable levels."
"Joint Reply Comments of the National Rural Telecommunications Cooperative and the National Rural Electric Cooperatives Association, ET Dkt No. 03-104, filed Aug. 20, 2003. (“Joint Reply Reply Comments, NRTC and NRECA highlighted the importance of broadband to rural America and noted that the two major broadband platforms -- DSL and cable modem – do not reach significant portions of rural America nor will they arrive there anytime soon.
"NRTC and NRECA , with their member rural electric cooperatives remain interested in BPL as an emerging technology, and have monitored BPL technology developments since 1997. Despite our desire for rapid BPL rollout, we caution that our research leads us to conclude that BPL technology will not be a viable solution in the near term for rural America."
These are the two organizations best able to speak for the needs of rural electric utilties and their customers.
Ed Hare, W1RFI
|
| |
|
Put BPL Proceeding on Ice for Further Interference
|
|
|
by K0ZN on May 13, 2004
|
Mail this to a friend!
|
You KNOW this is headed to the Courts. The FCC Commissioners are clearly motivated by something other than technical merit and are ignoring their fiduciary responsibility to protect licensed services. The Commissioners likely know that BPL is going to cause a lot of interference damage but are chosing to pretend the merits outweigh the damage for "whatever reason" is driving them. Clearly, BPL is the most ill concieved proposal in the history of the FCC; this Commission is going to leave a very notorious record.
One can only pray that if/when this gets into the Court system that the judicial system operates with more honesty and integrity than the FCC.
If we have a new President and Administration, it may help the Courts deal objectively with this issue.
If the ARRL has to sue on this, we all need to "dig deep" into our pockets and contribute. This would seem to be a text book case for a Class Action suit, as there certainly is a "class" (licensed radio services) that will be damaged by the Commission's actions... actually LACK of action to uphold their responsibility to protect licensed radio services.
This whole deal is both amazing and sickening.
73, K0ZN
|
| |
|
RE: Put BPL Proceeding on Ice for Further Interfer
|
|
|
by KD5IR on May 13, 2004
|
Mail this to a friend!
|
|
.......Well said, K0ZN!! You stated OUR case without allowing your emotions to jumble up the words as I have Done previously. I was so madd when I read about Bush's speech that you just want to put A Mickey Finn in his "Cold Beer". Anyway i will be sending my contribution to the ARRL , when they formally file suit. Actually, I'm wondering why they don't go ahead and file instead of waiting.....Oh well, we'll see , s.kuteman , kd5ir
|
| |
|
BPL Proposed Rule
|
|
|
by CALLSIGNPENDING on May 16, 2004
|
Mail this to a friend!
|
I have a few thoughts, FWIW:
1. I think K0RFD put the case for commenting in government proceedings, even when the odds are against you, as well as I've ever seen it put by anyone -- and, I must admit, more succinctly than I could have done.
Thank you, K0RFD!!
As a Member of Congress might say to a colleague on the House floor: "I associate myself with your remarks."
2. I agree with several of you that hams are probably going to end up in court.
I sure hope ARRL will be soliciting donations soon for a LEGAL Defense Fund, or maybe initiating a special LEGAL collection for the established Spectrum Defense Fund. It is NOT too early to get started!!!! (And ARRL can always initiate refunds if the substance of the final rule on BPL is acceptable)
Also:
Maybe some of ARRL's "deeper-pocketed" natural allies on this issue, such as ARINC, would be willing to share the expenses of a lawsuit.
3. Personally, as a lawyer, I remain truly puzzled by the risks the FCC is taking to shave a few months off the process of getting to a final rule on BPL.
The FCC's lawyers, and lawyers for the BPL-oriented energy utilities, must KNOW that the FCC's "high speed mode" in dealing with the NTIA study -- Phase II of which isn't even available yet!! -- is going to make the final rule MUCH more vulnerable in court than it would be if the FCC took 2 or 3 months longer.
Are the FCC and/or utility lawyers really so arrogant that they think they are above accountability to a court? OR are the corporate and Commission leaders so arrogant that they are not listening to their own lawyers on the little matter of "due process of law"? I DON'T KNOW, BUT FROM ****THE PRO-BPL PERSPECTIVE**** THESE TACTICS ARE RISKING A LOT FOR A LITTLE.
4. Finally -- Re President Bush and FCC Chairman Powell:
Without doubt, these 2 are pushing BPL -- and, for that matter, broadband/wireless services in general -- harder than any other politicians in Washington.
This is Reason No. 149 why I, personally, will be voting against President Bush. Not FOR Senator Kerry, mind you -- INSERT Grimace Here -- but AGAINST President Bush.
Having said this, however:
President Bush and FCC Chairman Powell may be the "ringleaders", but I haven't seen any Democratic Party politicians, on or off the Commission, opposing BPL -- or, for that matter, any other scheme to promote commercial broadband/wireless services at the expense of other spectrum uses with a higher value to society.
We really, REALLY need to figure out how to get that "third party" thing in gear!!
For THIS year, however, we're still in "lesser of two evils" mode -- and for me, when it comes to BPL, and 148 other issues, that means voting for The Weather Vane From Massachusetts over The Implacably Hostile Enemy In The White House.
That's just my PERSONAL opinion. My 2 most prominent clients, the NATIONAL ANTENNA CONSORTIUM and THE AMHERST ALLIANCE, remain bi-partisan (and, indeed, multi-partisan).
73,
Don Schellhardt
|
| |
|
Email Subscription
You are not subscribed to discussions on this article.
Subscribe!
My Subscriptions
Subscriptions Help
Other News Articles
Student Sends MIT Letter to Space:
Amateur Radio Club Talks to Hams Worldwide on Centennial:
New Communication Exhibit Helps Kids Get the Message:
Transmission of Images - No Internet, Satellite, Cable, or Cells Needed!
Deltona Youth Loves to Ham It Up on the Radio:
|
