From: Larry Staples
To: Larry Staples
Cc: Bruce Frahm , Wade Walstrom
Subject: BPL - Silver Lining?
Date: Mon, 18 Oct 2004 13:07:13 +0000
Dear List Member:
Those of you following the broadband over power line issue, should be interested in the following sent to us by our League Division Director, Wade Walstrom, W0EJ.
Larry Staples, W0AIB
I thought you would be interested in a response from Ed Hare regarding
the recent FCC R&O. Ed is correct, of course, but it is still up to
(Midwest Division Director, ARRL)
Here are some words I offered a member today:
Although ARRL is not pleased with all of the provisions in the rules changes, the end result is a LOT better than it started out to be. Back when this all started, at the Notice of Inquiry stage, FCC Commissioner Abernathy said that she felt that most of the rules restricting BPL could be removed. At that time, as now, BPL was legal under FCC rules, subject only to a requirement not to exceed the emissions limits (30 uV/m at 30 m -- typically an S9 noise level), a requirement to do their own testing and a requirement not to cause harmful interference. Had the FCC done nothing, that is the basis on which BPL could operate right now. That would have been the worst possible outcome. This rulemaking was not intended to permit BPL, because it was already permitted.
The end result is a lot different than Commissioner Abernathy had envisioned. Interference is now center stage, and four of the five Commissioners recognized this in their statements about BPL. The text of their statements are appended. Under these new rules, although the emissions limits have not been changed, neither has the unconditional requirement that they not cause harmful interference. In fact, the FCC has indicated that the rules will contain a step-by-step process to be used to resolve interference -- another first.
Not only has the Commission said that interference is important, groups like the IEEE BPL committee are also saying that resolving interference is important, and ARRL will continue to be part of that process. Several systems have shut down, in part due to interference issues, and ARRL will continue to be a part of that, too, if systems cause interference. The rules are expected to tighten up the testing requirements, and instead of allowing manufacturers to do their own testing, the FCC will become involved through the much more rigorous certification process. That is a major step forward. ARRL and others had requested this instead of verification.
No other unlicensed device is required to have the ability to remotely program operating frequency and power level (and shut off) built into the device. That is a step forward, too. No other unlicensed device is required to maintain a public database for interference resolution.
ARRL's work on identifying and reporting interference was very much a part of why BPL has new restrictions relating to interference that it did not have before. Its work on interference has that issue center stage with groups like the IEEE, and ARRL has a seat at that committee table. ARRL's analyses of the flawed technical testing done by several BPL manufacturers was very much a part of the FCC's decision not to allow manufacturers to authorize their own equipment any more. And ARRL worked closely with industry groups and other government agencies.
It made a difference, because without it, we would have been where Abernathy said she wanted to be, with restrictions removed instead of new ones added. The FCC truly believes that it has solved the interference issue. At least for amateur radio, if the FCC enforces its own rules, we will have to give that an opportunity to work. I disagree that this is a good solution, but the FCC could not simply walk away from the benefits of BPL, and it is hard to argue with those. By putting strict controls on BPL, it believes that it can coexist with other services. Amateur Radio may end up protected, at least to some extent. Unfortunately, other HF and low VHF spectrum, other than the frequencies the government unconditionally protected for itself, will not, and things like international shortwave broadcasting will be harmed.
The work is just beginning. ARRL helped to convince the FCC to reign in BPL from its initial dream of "most restrictions" being lifted. Now, it is make or break time for this industry. If they will design their systems to not cause interference, ARRL will help them by evaluating the systems and providing them information about what level of protection is needed. One manufacturer has already taken us up on that offer, and we are making plans to get together at one of their sites next month to see what they have done right so far. If they don't meet the goals, ARRL will continue to press interference complaints through the FCC, because is it critical that the FCC enforce its own rules.
So let's not give up. What has been done so far has made a major difference, and if anything, the harder work of working with hams, utilities, manufacturers and organizations is just beginning. If hams walk away now -- and some will -- they are giving up and letting BPL have its way.
Those who do walk away are leaving amateur radio at a time when they are needed the most. It is too important to me for me to do so, and I encourage you to stay with it. Ten years from now, amateur radio will still be around. By then, BPL will have been replaced by something even better. In the interim, we need to make sure that it is done in a way that doesn't make too many of us walk away, because without amateurs, amateur radio would be doomed. I will do whatever I can now to ensure that amateur radio has a future. I hope that all hams can count on each other to do the same.
The FCC and its rules say that when interference occurs, they will act swiftly to resolve it. This is a promise ARRL intends to help them keep.
Commissioner Copps: ------------------------
" I remain concerned with the question of interference to amateur radio users. I take the concerns of this community very seriously, and believe that the FCC has an obligation to work hard to monitor, investigate, and take quick action where appropriate to resolve harmful interference. If interference occurs, we must have a system in place to resolve it immediately. If an amateur radio user makes a complaint and an agreement between the BPL provider and the amateur radio user cannot be reached, the FCC should step in and resolve the matter. These cases must not take years to resolve."
Commissioner Adelstein: --------------------
"I take seriously our obligation under Section 157 of the Communications Act that "[i]t shall be the policy of the United States to encourage the provision of new technologies and services to the public." I am fully committed to that mission to promote new technologies, and to provide a framework for innovation so they can succeed. In order to do so in this case, though, we must ensure that sufficient protections are in place to limit interference concerns.
"Recent Access BPL test deployments have been very useful in developing techniques to address interference issues. It is clear that some Access BPL systems can co-exist very well with existing licensees in the HF and VHF bands. In the limited cases of increased interference, the Access BPL operators were able to quickly resolve and address the interference problem. Other Access BPL systems, though, have not fared so well, and these systems should not be deployed on a commercial basis if they will continue to result in harmful interference.
"We have put in place on Access BPL some special rules that are not normally required of Part 15 operators. However, I believe that these restrictions and requirements, such as adaptive frequency selection, remote shut down control, and a publicly available Access BPL database, are critical to providing an operational environment that safeguards existing licensees from harmful interference. I am also pleased to support our specific requirement for Access BPL providers to promptly respond to complaints of harmful interference from public safety licensees."
Commissioner Abernathy: -------------------
" We believe the new requirements we are imposing will help minimize harmful interference that may occur and, to the extent any harmful interference does occur, to quickly resolve any issues."
Commissioner Martin: ----------------------
"In this Order, we have attempted to facilitate deployment of BPL while ensuring that existing users are protected from harmful interference. Working closely with NTIA, we have taken strides to address interference concerns of both Government and private users. Nevertheless, I recognize that Amateur radio operators still have concerns that they will experience interference from BPL systems. In addition, broadcasters are concerned that BPL systems will cause interference in the low VHF band. I take these concerns - as well as the other concerns expressed about BPL systems causing interference - very seriously. I am confident that the Commission will continue to monitor these concerns and will take steps, where needed, to address interference problems going forward."
Ed Hare, W1RFI
ARRL Laboratory Manager
225 Main St
Newington, CT 06013
Member: ASC C63 EMC Committee
Chairman: Subcommittee 5, Immunity
Chairman: Ad hoc BPL Working Group
Member: IEEE SCC-28 RF Safety
Member: Society of Automotive Engineers