[ARRL-OK] ARRL BPL Article - Eddie KD5JGB

[Eddie Manley]

 From Eddie Manley -KD5JGB
This is one of the best well written articles on BPL that I have seen.   
Last night I saw a short news announcement that "President Bush wants 
internet access into every home in the US by 2007".   The BPL issue may 
be one of their plans of action, so besides making your feelings known 
to the FCC and our Congressional members, we might start to look at how 
it is going to affect us.   As you can see, it is already available and 
being put into use.   Let your Oklahoma ARRL leadership know how you 
feel about BPL.   Contact me: <jema1@arrl.net> or John: 
<wb5syt@arrl.net> or any other league official and let us know of your 
BPL situations.    ARRL BPL Article to follow:
================================
"It Seems to Us..." BPL: What Now?

By David Sumner, K1ZZ
ARRL Chief Executive Officer
March 26, 2004

Editor's note: Typically, only ARRL members get to read the "It Seems to 
Us ..." editorials that run each month in QST. We're posting this 
editorial that appears in the May 2004 issue of QST in the hope that 
both ARRL members and nonmembers might appreciate it and find it 
informative.

Understanding the issue and the best way to approach the FCC with 
comments is key in favorably catching the Commission's ear.

An important date is looming on the horizon: May 3, the deadline for 
comments on the FCC's Notice of Proposed Rule Making (NPRM) on Broadband 
over Power Line (BPL) systems, ET Docket No. 04-37.

The purpose of the NPRM is not to allow BPL to be deployed. BPL systems 
may now operate under the existing Part 15 rules. If the FCC did 
nothing, BPL systems could continue to be installed and operated. 
Licensed radio services, including the Amateur Radio Service, would 
continue to be protected by the rule that prohibits unlicensed devices 
from causing harmful interference. BPL systems would continue to have no 
protection against interference to their operation by licensed services.

The NPRM, which follows a Notice of Inquiry (NOI) in which the FCC 
sought information about BPL technology and the interference 
environment, does not propose to change any of that. Indeed, the NPRM 
reaffirms that the "no interference" principle must remain inviolate.

The NPRM proposes new requirements for BPL systems. The intent is to 
make it easier to track down who is responsible for interference and to 
make sure that the BPL system operator can immediately take whatever 
steps are necessary to mitigate interference. These include requirements 
that BPL systems "shall incorporate adaptive interference mitigation 
techniques" as well as "a shut-down feature to deactivate units found to 
cause harmful interference."

These proposed requirements need quite a bit of fleshing out to afford 
any real protection. They offer no practical relief from interference 
for mobile stations. We would have preferred a decision simply to ban 
BPL as a technology that stands to do more harm than good. The record in 
the NOI proceeding certainly would support such a decision.

Still, the FCC's proposals go a couple of steps in a positive direction. 
Certainly they should offer no comfort to the BPL industry, which is on 
clear notice from both the FCC and from us that interference will not be 
tolerated. Someone who makes an investment in BPL will have no grounds 
for whining when they lose their shirts.

So, why the hue and cry against BPL? There are several reasons.

There are BPL proponents who from the very beginning have denied that 
interference is a problem. They have continued to deny it even in the 
face of clear and mounting evidence to the contrary. Their comments 
filed in response to the NOI were laughable, as we pointed out on this 
page last October.

We have the FCC Chairman acting as a self-described "cheerleader" for 
BPL. Chairman Michael Powell says he will "welcome the day when every 
electrical outlet will have the potential to offer high-speed broadband 
and a plethora of high-tech applications to all Americans." Especially 
galling was to hear him say on February 12 that BPL could be "the great 
broadband hope for a good part of rural America." Anyone who has taken a 
serious look at the economics knows that this is a false promise. BPL is 
not a low-cost option, especially in sparsely populated areas. Who needs 
wires anyway, when Broadband Wireless Access is just around the corner?

We have the power companies' spotty record of resolving power line 
interference caused by electrostatic discharge. How can we believe they 
will do any better fixing problems caused by a technology with which 
they have no experience? There is one sentence in the NPRM that is 
guaranteed to arouse the ire of any active amateur. In discussing why it 
believes the likelihood of BPL interference is low, the Commission says: 
"We...expect that, in practice, many amateurs already orient their 
antennas to minimize the reception of emissions from nearby electric 
power lines."

Finally, the NPRM does not deal at all with a problem that concerns many 
amateurs almost as much as interference from BPL: interference to BPL. 
Yes, Part 15 says that "interference must be accepted that may be caused 
by the operation of an authorized radio station." Try explaining that to 
your drunken neighbor when he can't download his dirty movie because 
you're on 20 meters.

Still and all, the best approach in responding to the NPRM is a positive 
approach. Yes, we would have preferred a ban on BPL, but the FCC hates 
to pick winners and losers. They prefer to "let the marketplace decide." 
The rules they have already proposed make it even less likely that the 
marketplace will decide in favor of BPL, but that is someone else's 
concern. Our concern is to support the FCC's proposals as far as they go 
(remember, they're better than the status quo), to document exactly how 
they fall short of providing the protection that over-the-air 
services--especially the Amateur Radio Service--need and deserve, and to 
provide specific proposals for improvement.

The improvements we have in mind include:

Performance standards for interference mitigation. Mitigation must be 
available 24/7, and must be immediate upon receipt of a complaint.

The BPL data base must be readily accessible to the public and kept up 
to date.

Because mitigation is impractical in the case of mobile stations, a 
radiated emission limit sufficient to protect mobiles must be 
established and enforced.

BPL systems must be tested for rules compliance by an independent 
laboratory prior to initiation of service.

To ensure an informed marketplace, marketers of BPL services must give 
clear notice to consumers that licensed radio services have priority and 
that the delivery of BPL services therefore cannot be guaranteed. 
Receipt of this notice must be acknowledged in writing prior to the 
signing of any contract for service.

There must be severe penalties for non-compliance with these rules.

If you want to file comments -- and we hope you will -- read the NPRM 
first! Pay particular attention to paragraphs 39-43; the FCC asks for 
comments on several aspects of its proposals. The NPRM is available on 
the FCC Web site in Microsoft Word and as an Adobe PDF file.

How the FCC handles BPL is important, but the most important decisions 
about BPL deployment will not be made at the FCC. They will be made in 
corporate boardrooms; the smart money will choose to go elsewhere, not 
to BPL.