For information, here is the action that we in the Potomac Valley Radio Club
are taking. PVRC is a contesting club with several hundred active members in
the mid Atlantic region. I am the current President, and Jim Talens, N3JT is
a lawyer and engineer who has many years of FCC experience. Jim led the
action for our previous submission to the FCC on the BPL issue. This activity
may
be of interest to you. Any supporting input may be directed to Jim, who is
cc'd.
Jack Hammett, K4VV
The FCC Notice of Proposed Rule Making (NPRM) about BPL is available at
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-29A1.doc
Comments will be due 45 days after the NPRM is published in the Federal
register.
I read the NPRM yesterday, and it has some hopeful aspects about protecting
other services from interference, but there are clear signals of a steamroller
with momentum speeding forward. BPL is viewed as a tremendous national asset,
which has importance that outweighs other considerations. There is a lot of
weight given to adaptive interference avoiding technology with very little
basis offered, other than the cheerful inputs from the industry that gains from
BPL. The FCC conclusion is to press ahead, and work the interference issues as
we go. We need to make a serious review and comment.
Jim Talens, N3JT has prepared some very helpful suggestions on how to
respond. His message follows. Please read Jim's input and the NPRM. We need
volunteers willing to put in some effort to generate comments for PVRC, and
later to
review other comments, and write some more. Your technical talent and
operational experience could make a real difference here for the future of
amateur
radio. Please let me and Jim know your willingness to help.
Jack Hammett, k4vv
------------------------------------------------------------------------------
----------------------------------
Subj:BPL Initial Proposal
Date:2/25/2004 1:19:10 PM Eastern Standard Time
From:jtalens@rcn.com
To:k4vv@aol.com
Sent from the Internet (Details)
I have read the NPRM on BPL and have some comments and suggestions on how we
might respond as a club. First, though, the Comment date is not yet fixed
because it will be 45 days after the NPRM appears in the Federal Register,
which has not occurred yet. Reply Comments are due 30 days after that.
I'll try to find out when the Federal Register insertion occurs so we know
when the Comments are due. Below there are two sections, I and II. Section
I deals with the NPRM. Section II addresses my thoughts on how to file and
participate, club and individuals.
As we did with the NOI, I propose we follow the sort of approach outlined
below. I can try my hand at responding to many of these issues, but not the
technical ones. For those, we need members who can make convincing
technical arguments (and don't mind some editing along the way, just as I
will be edited). In the Reply Comment stage, we'll need a bunch of folks to
summarize the pleadings from the FCC website.
I. NPRM
It is incumbent on everyone who has an interest in the future of ham radio
to read the NPRM. It takes less than an hour, because the main document is
only 20 pages long and much of it reads quickly.
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-29A1.doc The
Appendix B part is important because it contains the actual rule proposals.
Appendix C is critical to the technical folks because it contains the
measurement technique part, discussed above
I think the FCC did hear the amateur community in the NOI stage of this
proceeding, but it was not entirely convinced. The NPRM tries to take a
midway path through the need to provide BPL (which at this point we must
accept as unstoppable unless Congress overrules the FCC, which is unlikely
given the relative strength of the power companies compared with the ham
community and its allies, notwithstanding one of those allies potentially
being DoD) and protecting licensed services such as ham radio. The NPRM
contains a series of technical questions and some policy questions. Here
are a few of them:
1. At para. 33 the conclusion is drawn that there are remedies that can be
used to eliminate the BPL interference. This conclusion has to be mentioned
repeatedly as justification for later procedural changes we will propose to
make sure that such remediation can and will happen.
2. At para. 35, there is a bad finding: that power line noise level
already exists, suggesting that a little more power line noise is not a big
deal. This has to be vanquished. First, the power company at least in No.
VA has been very cooperative and responds to complaints about noise sources,
which typically are from defective hardware. So the normal noise
environment is and must remain quiet. That noise from power lines is
already a significant problem for amateurs is not justification for dealing
with yet another source. Rather, it is one that is vastly more pernicious
and difficult to identify, and hence requires special procedures and
protections if licensed services are to survive (like ham radio, the
ultimate last resort for homeland security).
3. At para. 35 (toward the end), the FCC says that it would expect hams
point their antennas to minimize reception of emissions from power lines.
This has got to be corrected, and the correction must be expressed so that
it in fact shows that such directive antennas make the susceptibility even
worse. Somebody technical needs to address this in convincing detail.
4. At para. 36, the FCC acknowledges the falsity of BPL's arguments that
there is no cumulative effect from multiple Access BPL devices transmitting
at the same time in the same area. It therefore requires that measurements
of emissions be taken (see Appendices B and C) that include readings at
various distances from the equipment source. We need somebody to provide
technical comments on this proposal so that we can be sure that any emission
measurements are fair to us. There is another issue. The BPL providers
seem to claim that only discrete frequencies will be used as part of their
modulation scheme. Somebody who is more knowledgeable than I about Part 15
and the use of CDMA or other modulation techniques needs to provide
refutation. That is, if CDMA can be used, the signals are cumulative by
definition and no mitigation is possible except by filtering.
5. Para. 37 addresses non-amateur safety services. But maybe we should
claim we are public safety service providers as well (See Part 97) and in
any event the importance of such services is BEFORE interference occurs.
That is, what good is a remedy to cure interference AFTER the emergency
occurs? It is therefore critical that the power companies cease their
service upon notice of possible interference. More about this later.
6. Para. 39. What happens if a ham moves into a neighborhood where BPL
already exists? He is licensed but he gets interference. We must make it
clear that he still is licensed and has an absolute right to have the source
shut down. "Thus, operations must cease if harmful interference to licensed
services is caused." The FCC talks in terms of BPL having an incentive to
avoid interference because of its investment in plant. That cuts the other
way: they are less likely then to be willing to shut down if there is a
complaint of interference. Something has to be included in the rules to
assure that they cannot stonewall on receipt of a complaint.
7. Para. 40. BPL operators would be able to modify system performance to
mitigate or avoid harmful interference to radio services. What is
"harmful" and who makes the choice about whether to "mitigate" or "avoid"???
Avoid means to prevent; mitigate means to fix afterwards. We should
definitely require pre-operational notice to local hams or clubs so hams can
deal with the issue before subscribers become wedded to their services. And
that leads to a big, big issue: Hams may interfere with BPL. Once there
are 50 subscribers in a neighborhood, what happens when the ham insists on
shutdown from interference on HF? Do 50 subscribers just stop having
Internet access and die? No, they complain like crazy to their Congressmen
and Senators and to the FCC, and where does our ham radio public interest
value weight-in against that kind of complaint? The FCC has not addressed
this at all and it must make statements assuring hams and other licensees
that interference to BPL by hams will be acceptable. In fact, Part 15 by
its very terms assures that, but raising the issue gives us ammunition in a
future proceeding that might change the right of licensees to shut down BPL.
8. Para. 42 is the key paragraph on interference complaints. It is
critical. Questions must be addressed here: Who hits the "shut-down"
feature to deactivate interfering units? Will a ham who has a portable
receiver be able to implement that shut-down by telephone/written statement
to the power company, or must he get a power company technician out to
confirm interference (4 weeks later and with an answer of "I don't detect
any interference")? What does "have the capability to remotely exclude a
specific percentage of frequencies within this range" mean? Should we argue
for filtering of all ham radio bands? (I think so!) What about future ham
radio bands through future WRC enactments? Will power companies have to
include those in their filters? (YES!) Finally, and most critically, how
will BPL providers and manufacturers "work with amateurs"? Does that mean
ARRL should be authorized to speak for all hams to develop mitigation
requirements (and procedures, which are not mentioned)? Procedures are
important. What exactly happens if a ham thinks he has interference from
BPL? Call the power company and ask nicely for a technician to take
measurements? Should there be a 48-hour response requirement with a written
report provided to the amateur? Should hams have the right to have the BPL
service shut down if he/she detects interference and provides a technical
finding (violative of the rules) to the power company, i.e., pending a
demonstration by the power company that the power line is clean? Should the
BPL service providers be REQUIRED in all notices and contracts for BPL
service information that a complaint of interference from an amateur public
safety service provider may cause cessation of service without notice? At
the last sentence of para. 42, we should say that currently deployed systems
should come into compliance within 180 days.
9. Para. 43. Important issue: The database for BPL should include all
complaints filed and the amateur community should have representation on the
"industry-operated entity." There must be a requirement that the database
be kept up to date with all new information submitted and reflected in the
database within 5 working days of completion or complaint filing. Should
there be a central database or a regional or local one? I would suggest a
national one with web access by anybody without charge. As for proprietary
information, we can anticipate the power companies will claim that their
systems are operating in a competitive environment and they don't want to
reveal what equipment they are using, but in fact we should not let them go
there. They MUST reveal frequencies, modulation techniques, topology, etc.
Some additional issues:
1. At paras. 20 and 21, Access BPL proponents say that there have been no
complaints of interference from BPL. Is this true? Did AMRAD or has anyone
else run any tests or do we have any local evidence of interference? Even
if we do not have this information, it seems to me that this is hardly a
realistic justification for ubiquitous deployment of BPL. That's like the
old statement of a vendor that they've never gotten a complaint before
yours! First, nobody who even gets interference knows what is causing it,
let alone who is causing it or how to get in touch with the interferor. So
this issue needs some work by somebody who can perhaps contact AMRAD and
find out what's going on with them. But this is in the "summary of
comments" section and is not really an area we would comment on. Still, we
can refute the finding if it is wrong. Somebody technical needs to contact
AMRAD on this and prepare text.
2. At para. 22, BPL proponents argue that predictions of interference are
incorrect because power lines will not act like antennas. They say that
the power lines will tend to cancel each other out. They say that the
powerlines can look like point sources. We need a technical expert to
refute this with convincing technical language. All of the material in
para. 22 needs to be refuted. Somebody technical needs to contribute
language on this one.
II. Approach Proposals
1. We file our comments via electronic means on the due date. We can share
our filing with other entities (including individual members), but multiple
filings of the same text tend to make our work look like it's an effort at
stuffing the ballot box. We might share our draft with those who can
rewrite it and submit it as their own. That would include club members.
Comments?
2. We review a sampling of filed comments and prepare our Reply Comments.
3. With our initial comments, we send hardcopy via fax or letter to the
Commissioners, their staff members and all other FCC staffers who are known
to be interested in or working on this project. There are probably 75-80 of
them.
4. We prepare a cover fax sheet and send a strong letter to ALL U.S.
Congressmen and Senators, attaching our comments. Somebody has to do that.
I think email can be deleted and/or stuck in a folder too easily. The timing
of this is not as critical as the original filing, but it should be done in
the days that follow our filing. Same for our Reply Comments later.
5. I at first thought that appearing en masse in front of the FCC would be
good, particularly if we could get some press coverage. On second thought,
I think it would be impossible to express our concerns in a the 6-second
byte that TV requires, and it all might annoy the Commissioners and
undermine the efforts of ARRL and ourselves. I would not do that.
These are my initial comments. Others may take issue with all or part of
what I have offered, but we have to get started soon. There's lots of work
to be done, and it's very important.
Jim Talens
(h) 703.241.1144
(cell) 703.850.1600
_______________________________________________
RFI mailing list
RFI@contesting.com
http://lists.contesting.com/mailman/listinfo/rfi
|