[CW] A backup plan if BPL fizzles?

[David J. Ring, Jr.]

Here is what is at that URL, I don't see NASWA anywhere!

73
DR

Ken wrote:
Check out this comment by NASWA (a SWL organization), maybe the FCC
really does read those comments, though I'm sure they'd never give
credit to a bunch of hobbyists for an idea.

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6516182864

I found:

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the matter of )
)
Carrier Current Systems, including ) ET Docket No. 03-104
Broadband over Power Line Systems )
)
Amendment of Part 15 regarding new )
requirements and measurement guidelines )
for Access Broadband over Power Line ) ET Docket No. 04-37
Systems
JOINT COMMENTS OF
The Association of Public-Safety Communications Officials-International,
Inc.
(.APCO.), and the National Public Safety Telecommunications Council
(.NPSTC.)1
(collectively referred to herein as the Joint Parties), hereby submits these
comments in
response to the above-captioned proceeding. Both of these organizations
represent
members involved in public safety communications.
BACKGROUND
In this NPRM, the Commission proposes among other items, certain rules and
restrictions
on new Broadband Power Line (BPL) systems to minimize harmful interference
to
licensed services. It is the potential for harmful interference to licensed
public safety
1 The members of NPSTC include: American Association of State Highway and
Transportation
Officials, American Radio Relay League, American Red Cross, Association of
Public-Safety
Communications Officials-International, Forestry Conservation Communications
Association,
International Association of Chiefs of Police, International Association of
Emergency Managers,
International Association of Fire Chiefs, International Association of Fish
and Wildlife Agencies,
International Municipal Signal Association, National Association of State
Emergency Medical
Services Directors, National Association of State Telecommunications
Directors, and National
Association of State Foresters.
radio systems that concerns the joint parties. The joint parties see the
merit of new
technology that can potentially provide broadband data to under served rural
areas. This
potential must not be allowed to come at the cost of harmful interference to
public safety
radio systems in the HF (2-7 MHz), low VHF (30-50 MHz) bands and the 72 to
76 MHz
band.
DISCUSSION
In the NPRM, the Commission states its belief that the risk of harmful
interference to
public safety systems is low. To date the joint parties have seen no
comprehensive test
programs that validate the Commission's beliefs. On the contrary,
preliminary data
gathered in the United States and abroad points to the potential of
significant interference
in spectrum shared with BPL technologies. The NPRM goes on to propose
measures to
mitigate harmful interference to public safety systems if such interference
occurs.
However, these measures are reactive, not proactive. The measures will be
implemented
only after interference occurs. In addition, it appears the burden of
identifying cases of
interference is placed on the public safety user. Considering the rural
nature of public
safety operations in the VHF low bands, the only way a public safety agency
will know
that interference is present in a given location will be when an officer
cannot
communicate in that area. This will compromise the safety of both officers
and the
public they serve. Furthermore, this is a distributed technology that, by
its very nature,
will make it difficult to isolate interference points. The reality is that
the overall effect of
BPL implementation will be a potentially significant increase in the noise
floor rendering
impossible otherwise acceptable mission critical public safety
communications. In
attempting to identify the source of the interference, the public safety
agency will have to
know what the noise floor was prior to the BPL system being installed, with
no real way
to disable such a distributed system to make these baseline measurements.
The HF band (2-7 MHz) is widely used by state emergency management agencies
to
coordinate disaster response. The VHF Low Band (30-50 MHz) is used by many
first
responder agencies (EMS, fire and law enforcement), as well as public safety
support
services. The 30-50 MHz band is used significantly by thirteen states for
state police
operations (with nine, including California, using it as their primary
band)2. Importantly,
these public safety systems are typically concentrated in rural areas where
the most
significant use of BPL is anticipated. Public safety equipment in the 30-50
MHz band is
typically vehicle mounted, and may include ¼ wave antennas mounted on the
deck or
roof of vehicles such that the antennas could be very close to power lines
carrying BPL
signals. Because public safety radios are vehicle mounted, users typically
traveling down
roadways could anticipate being next to power transmission lines and their
associated
BPL signals over a significant portion of their vehicle service area since
utility rights-ofway
typically follow public roadways.
The band from 72 to 76 MHz supports fire alarm callbox systems generally
limited to one
watt of transmitter power. The low power and one-way transmit nature of
these units
2 CA, CT, FL, IL, IN, MS, MO, NE, NC, SC, TN, WV, WY
make them susceptible to BPL interference. In many cases, these alarm boxes
are the
sole means of reporting fires in commercial properties.
Amateur operations in the HF band may receive interference from BPL. The
joint parties
are aware of the great concerns amateur operators are expressing for the
potential
interference from BPL. Amateurs provide valuable communications support to
public
safety during disasters. Any harmful interference to amateurs in the HF
bands will
disrupt those valuable services from the amateur community.
Public safety experiences with reactive measures to identify and mitigate
random
occurrences of interference in location and time are not good. As these
Joint Comments
are being written, the Commission is considering how to deal with
interference in the 800
MHz band. It appears, wide spread implementation of BPL systems could lead
to the
same widespread random destructive interference now occurring in the 800 MHz
band
being introduced into both the HF 2-7 MHz "Operation Secure" and VHF 30-50
MHz
bands. A belief that interference potential is low is not the same as
knowledge that the
potential is low. The joint parties strongly assert that knowledge should
replace beliefs
when there is risk to public safety operations and, to the delivery of
mission critical safety
of life and property services to the pubic at large.
It certainly is not to the benefit of the companies implementing BPL systems
to be
continually correcting cases of interference. They could be faced with the
need to stop
providing service or only providing very degraded service if cases of
harmful interference
are higher than the Commission expects. The joint parties do not want to be
in the
position of demanding that BPL operators cease operating due to harmful
interference to
public safety radio after these companies have made large investments in BPL
infrastructure. This would be in no one's interest.
The joint parties urge the commission to call on the BPL operators to fund a
yearlong
demonstration system of sufficient scale to prove that harmful interference
to public
safety and amateur radio operators will be rare. The joint parties to date
can find no real
world demonstration that conclusively shows BPL systems will rarely or never
cause
interference to public safety or amateur systems. The joint parties
acknowledge that this
recommendation will raise concerns of delaying a new technology. However, we
note
that public safety users have been waiting since 1996 for use of 24 MHz of
spectrum and
the new wideband data technologies promised in the 700 MHz band. A one-year
delay
that allows proof of rare or no interference seems to us to be a small
price. Fielding this
technology, without a demonstration, would leave the public open to
absorbing
considerable expense either directly or indirectly should the technology end
up being
unusable. Costs of decommissioning would be born directly by the subscriber
due to the
purchase of then unusable equipment, or, if BPL subscribers were reimbursed,
paying the
costs born by their utility provider to fund the reimbursement. Failure of
the BPL
technology leaves the public as the loser both from a public safety
standpoint and as the
ultimate funding source for a failed experiment. Thus, such a demonstration
project
would decrease the risk to the Commission and to the public of needing to
deal with
another 800 MHz catastrophe in the HF and VHF bands some years in the
future.
SUMMARY
The joint parties are not opposed to BPL technology. We do oppose
introduction of any
new technology that will interfere with vital public safety communications.
With this
technology, even the Commission acknowledges there is potential for harmful
interference. Because there are no real world studies designed to gage the
interference to
public safety, the joint parties are very concerned that the HF and VHF
bands will receive
random harmful interference. To resolve these concerns, the joint parties
urge that a
yearlong demonstration project be undertaken to show rare or no interference
from BPL
systems.
Respectfully submitted,
/s/
Vincent R. Stile, President
Association of Public-Safety Communications Officials International
351 N. Williamson Blvd.
Daytona Beach, FL 32114-1112
Marilyn B. Ward, Chair
National Public Safety Telecommunications Council
NPSTC Support Office
NLECTC - Rocky Mountain Region
2050 E. Iliff Avenue
Denver, CO 80208
----- Original Message ----- 
From: "Ken Brown" <ken.d.brown at verizon.net>
To: "Lawrence Makoski" <Makos327 at worldnet.att.net>; <cw at mailman.qth.net>
Sent: Friday, May 14, 2004 11:43 PM
Subject: Re: [CW] A backup plan if BPL fizzles?



Check out this comment by NASWA (a SWL organization), maybe the FCC
really does read those comments, though I'm sure they'd never give
credit to a bunch of hobbyists for an idea.

>http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_docume
nt=6516182864
>
>
DE N6KB


_______________________________________________
Cw mailing list
Cw at mailman.qth.net
http://mailman.qth.net/mailman/listinfo/cw