ARRL Seeks Clarification of FCC Response to BPL Interference Complaint:
from
The ARRL Letter, Vol 23, No 30
on
July 30, 2004
Website:
http://www.arrl.org/
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ARRL Seeks Clarification of FCC Response to BPL Interference Complaint:
The ARRL wants the FCC to further explain its recent response to a North
Carolina amateur's complaint of BPL interference. FCC Office of
Engineering and Technology (OET) Deputy Chief Bruce A. Franca replied July
22 to an April 27 BPL interference complaint from Thomas A. Brown, N4TAB,
of Wake Forest. Brown had complained of BPL interference to his amateur HF
mobile station emanating from a Progress Energy Corp (PEC) BPL field trial
in the Raleigh area. In his letter, copied to ARRL, Franca said an on-site
investigation had concluded that PEC's BPL trial "is in compliance" with
FCC rules and that the company's ham band notching efforts "are effective"
to avoid the potential for harmful interference. ARRL CEO David Sumner,
K1ZZ, however, cited evidence to the contrary.
"It is not at all clear that the tests and measurements taken by the FCC .
. . established the absence of harmful interference to licensed stations,"
Sumner responded July 22. He said the League would like the OET to make
its test report available to the general public or at least to the League
for technical review and comment. The ARRL also wants to know what steps
PEC took between April 27 and June 28--when the FCC began its testing--to
address interference complaints from Brown and several other radio
amateurs.
The FCC defines as "harmful" any interference that "seriously degrades,
obstructs or repeatedly interrupts a radiocommunication service operating
in accordance with the Radio Regulations."
According to Franca, FCC personnel "undertook extensive testing and
measurements" of the PEC BPL system between June 28 and July 2. The
complainant--Brown--says the FCC delegation never contacted him while it
was in North Carolina. Franca says FCC measurements indicated notch depths
averaging 24 dB below Part 15 emission limits, which he characterized as
"sufficient to eliminate any signals that would be deemed capable of
causing harmful interference, including interference to amateur
operations."
Franca maintained that "in no instances" were signal levels high enough to
"cause serious degradation, obstruction, or repeated interruption" of
amateur mobile or fixed communications. He conceded, however, that
notching on 10 meters was somewhat less effective at the low end of the
band and said the FCC would instruct PEC and its partner, Amperion, to
widen its notch there.
Sumner noted that the Part 15 device operators "must eliminate all harmful
interference, and therefore in some cases must achieve more--in certain
cases, considerably more--than a 24 dB reduction in order to be in
compliance." He also cited recent reports from amateurs in the area
indicating that strong BPL interference continues in parts of the PEC
trial zone.
Sumner told Franca that amateurs in the Raleigh area on July 17 and again
July 22 monitored a BPL signal "at full strength and causing harmful
interference" from 14.290 to 14.350 MHz. "Harmful interference" also was
reported in the first 100 kHz of 15 meters as well as on the WWV/WWVH
frequencies of 15.000 and 20.000 MHz and on several international
broadcasting bands.
"Even in the notched bands," Sumner said, "the interference was still
evident on ordinary amateur equipment." He said it's clear to ARRL that
the system's Holland Church Road site--where the most recent amateur
measurements were taken--is in violation of Part 15.
For his part, Brown--an engineer with considerable RF experience--said he
was glad the FCC finally took some action but found some of Franca's
assertions "very troubling." He told ARRL that his 14-page complaint cited
interference "sufficient to mask a weak signal," although it did not
register on his S meter. An active Amateur Radio Emergency Service
District Emergency Coordinator, Brown said it's not unusual to have to
copy similarly weak signals during an HF emergency net.
"I suspect the principal reason for their coming down here was to say
they've actually done something," Brown commented. He also worried that
the FCC was attempting to define a standard of "acceptable interference"
within the framework of what constitutes "harmful interference."
"If it interferes, it interferes," he maintained.
Sumner also requested that the FCC clarify some additional aspects of its
North Carolina testing and measurement activities.
"Until these points can be clarified," he concluded, "we trust that the
Commission will not permit its conclusion to be erroneously represented as
having given the Progress Energy trials a 'clean bill of health.'"
Source:
The ARRL Letter
Vol. 23, No. 30
July 30, 2004
This article has expired. No more comments may be added.
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ARRL Seeks Clarification of FCC Response to BPL In
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by KF7CG on July 30, 2004
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I think we have seen where the line is drawn in the ether.
I just wonder how long it will be before 24 is rounded down to 20 and 10 accepted as good enough?
There was a very nice new posting about a marine rescure that partially depended upon Amateur radio both in the US and overseas that would not have happened if BPL had be in wide deployment. But that was only two people sailing in the Pacific.
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RE: ARRL Seeks Clarification of FCC Response to BP
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by AE1X on July 31, 2004
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That's right, but the problem is that someone in another country would have provided the assistance.
The FCC has indicated that the 90 year old model for spectrum management is out dated and is stifling telecommunications growth because they can not just allocate space based on an economic model.
They will have to decide whether it is best to use the economically driven model and go to a WRC for an exception or stick with it until a WRC decides to change models.
The amateur radio service under the old model controls some very valuable spectrum. This spectrum is allocated exclusively for the amateur radio service internationally. The FCC will have to either rellocate it and face the consequences at the next WRC and push for the new uses or get an exception like Shortwave Broadcasting has enjoyed for so long.
Concerning interference, this FCC believes that it can assign suitable sharing partners for all spectrum that it feels is under utilized. One of the things mentioned in the joint spectrum management statement recently was a study to determine the actual occupancy of various segments of the spectrum with an eye towards locating lightly used spectrum and using this information to drive the allocation of secondary sharing partners for those segments deemed under occuppied. In addition, there seems to be a feeling that an interference floor can be defined below which services can expected to be protected.
The FCC sees it as our mission to figure ways to use our allocated spectrum effectively while sharing it with other partners. I don't think this FCC is interested in our arguments that we need to be able to hear signals right down to thermal noise or atmospheric noise to accomplish the goals set forth for our service. They figure that we will just take up the challenge and develop effective ways to circumvent the interference which will be good for everyone involved.
You could take it that we will likely retain our allocated spectrum, but we will only find a small portion of it available for the weak signal type activities we engage in now. You want to rag chew, find an appropriate frequency and share it with others. It's as simple as that.
The FCC wants to change how spectrum is allocated and utilized to fulfill its vision for the future. A future far different than we would envision.
Ken
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RE: ARRL Seeks Clarification of FCC Response to BP
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by KF7CG on August 1, 2004
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The problem is that there were a several other countries involved and it took all of the resources available to make the rescue work.
I talk with anyone I can contact on the HF bands, but enjoy working the weakest signal that I can get to respond to my call. This is a form of stress reduction. Without this stress reducer I tend to develop a tendency to make a much trouble as legally and ethically possible for cause of the stress. In other word, excess stress breeds lack of tolerance.
That is why I compare deploying BPL with placing a dam across the end of the Grand Canyon and filling it to generate hydropower, or capturing the geothermal energies of Yellowstone for power. Both are a better economical deal, but both ruin the usability of an irreplacable natural resource.
Let economics prevail, dam the Grand Canyon.
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RE: ARRL Seeks Clarification of FCC Response to BP
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by WA4MJF on August 5, 2004
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Progress Energy threw in the towel today and
backhandedly gave "credit" to hams. Good job
KN4AQ, N4TAB and W4FAL!
73 de Ronnie
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ARRL Seeks Clarification of FCC Response to BPL In
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by AE1X on August 6, 2004
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It's great news to hear that the NC trial is ending shortly. The word from PEC was that the trial was a success, whatever that means.
The big question for BPL and the FCC is still the response by Mr. Franca concerning the 24dB nulls that he measured and the statement that these are sufficient to prevent 'harmful interference'. My response is BULL! The nulls may be 24dB down, but the problem is that they can not achieve this level of attenuation over the entire 20m band or any band for that matter. That is why I made my previous statement that we may find only a part of allocated bandwidth available for weak signal work.
An even bigger problem here is that an FCC official appears to be giving the impression that there will be a noise floor below which a service can not expect that it will be protected from co-channel interference. This raises the spectre of the FCC legislating the noise floor for each service or even for each segment of each service to accomodate new applications. They are messing with the definition of 'harmful interference' and trying give it their own definition a part from that in the international treaties.
It's great to have another service off the air, but the battle lines are still be drawn. Read the strategic plans published by the FCC on its website. You will get a better picture of where the FCC sees spectrum management is headed. It does not match our needs or expectations.
Ken
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ARRL Seeks Clarification of FCC Response to BPL In
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by AE1X on September 1, 2004
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Well, I think it's clear what is going on with the FCC and the interference complaints that are being ignored. The FCC is recording the complaints for the formal record only. Remember these are engineering trials and even some are operating under STA authority. Each of these trial cases must have a formal record and be permitted to operate to completion. The results of these trials will become a part of the formal procedings of the NOI and NPRM leading the final order.
Once the rules are set and a full commercial operation is in place and commerce begins, then the operators have the obligation to abide by Part 15 and then the FCC will have to come down on these operations when interference is reported.
Ken
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