[EIDXA] KN4AQ's 4th Complaint to FCC
Jim Spencer
jlscr at mchsi.com
Sat May 22 11:05:41 EDT 2004
In a message dated 5/21/2004 1:57:58 PM Eastern Standard Time,
kn4aq at arrl.net writes:
This is a copy of the complaint I filed today with the FCC. None of the
hams I've talked to who have filed complaints have received a reply from the
FCC, although we have informal assurances that our complaints have been
received. As far as I know, the FCC has not directed any utility to make
any changes or turn off any BPL systems.
At this time, the complaints are being handled by the OET, not by the
Enforcement Bureau.
73,
Gary KN4AQ
-------------------------------------
To:
James Burtle, FCC
Len Anthony, Progress Energy Regulatory Affairs
From: Gary Pearce KN4AQ
116 Waterfall Ct.
Cary, NC 27513
919-380-9944
kn4aq at arrl.net
cc:
Bill Godwin, Progress Energy
Anh Wride, FCC
Ed Hare, ARRL
Frank A. Lynch, ARRL
Thursday, May 21, 2004
This e-mail letter is an update of my third formal complaint of
interference received from several Broadband over Power Line (BPL)
installations operated by Progress Energy in the Wake County, North Carolina
area, submitted on May 12, 2004. I'm updating it to directly address Mr.
Burtle of the FCC, in case there was any confusion that I requested FCC
action and a reply on the complaint, and to add that my May 4 observations
were confirmed by a subsequent observation on May 19, 2004.
This complaint covers the continuation of interference noted in my second
complaint, filed March 29, 2004. This interference has not been addressed
as of an observation I made on May 4, 2004, and verified again on May 19,
2004, notwithstanding the claim in Mr. Anthony's April 20 e-mail to James
Burtle that, "Since that time, further modifications have been made to
address this fringe interference." (My complaints #1 and #2 are included at
the end of this e-mail, for convenient reference.)
Before detailing the interference I monitored on May 4 and May 19, I must
address the question of "what is harmful interference" in general, and the
question of harmful interference to mobile operation, which Mr. Anthony
dismissed in his April 20th e-mail.
First, the question of harmful interference. Amateur radio operators
frequently operate at the margins of signal strength and quality. Signal
strengths so weak that other services would consider them unusable are used
routinely for amateur radio communication. We also tune across spectrum
that contains no signals at all, looking for stations to contact. In our
receivers, in the single sideband (voice) mode, Progress Energy's continuous
series of BPL carriers appear as an always-present series of audio tones.
The pitch of the tones depends on the exact frequency tuned, but there is
always a tone somewhere in the prime spectrum for communications-quality
audio, between 500 and 2500 Hz. This "seriously degrades" our radio
communications service whether desired signals are being completely obscured
or not.
Yes, this means that interference just above the ambient noise level at
any given amateur radio station is harmful, as it changes the routine nature
of operation that we have enjoyed since shortly after the dawn of radio.
Progress Energy is attempting to overlay a second, unlicensed radio service
atop the spectrum allocated to a licensed service using Part 15 Rules that
were never intended to apply to signals of this combination of coverage and
duration. We will have no complaint if there is truly no interference, if
that can be accomplished. The technology you have deployed today does not
come close to meeting that goal.
Second, mobile operation is a perfectly valid form of amateur radio
communication, and interference to it is no more acceptable than
interference to fixed operation. The ability to drive away from
interference may be an option for a mobile operator, but that does not
remove the Part 15 liability of the operator of an unlicensed device to
avoid harmful interference, for several reasons. The mobile operator may
drive in and out of multiple interference zones as he or she travels down
the road. The mobile operator may be in heavy traffic, or may be stopped by
a traffic light, and what would be a minute of interference at 35 mph could
extend to several minutes. And the mobile operator may stop in a driveway
or parking lot for an extended period inside an interference zone. With no
practical way to immediately mitigate this interference, the mobile
operation will be seriously degraded.
In addition, keep in mind that Progress Energy is operating small trials
in neighborhoods where there are no amateur radio operators. In these
neighborhoods, we use mobiles as surrogates for fixed stations. In this
role, the mobiles have a serious handicap. Their inefficient antennas do
not permit reception of BPL signals at anywhere near the distances that even
simple dipole antennas at fixed stations do. To be specific, when driving
away, perpendicular to the active overhead power line, the BPL signal fades
to inaudible in 400 to 500 feet (not, by the way, the 90 feet Progress
Energy suggested in comments on the Docket 04-37 NPRM). However, home
stations, using dipole antennas, can hear the signals well as much as a mile
away. Danny Hampton K4ITL lives on Rock Service Station Road, just north of
Pagan Road, eight-tenths of a mile from the extractor on Holland Church Road
near Feldman Road. In our January 15 observation (and many times since), he
was able to hear the signal on that overhead line using a dipole antenna.
So to summarize these points, weak signals can and do create harmful
interference, mobile stations are fully legitimate targets for harmful
interference, and we are using mobiles to provide observations that would
otherwise be available if there were any hams living in the trial areas.
Now, on to my May 4 observations.
On May 4, I positioned my mobile amateur radio station at the intersection
of Holland Church Road and Elsie Lorraine Road, at the entrance to the
Holland Meadows subdivision. This is near the power line used for BPL
feeding the neighborhood.
I received signals with the Amperion "BPL signature" (mostly unmodulated
carriers, 1.1 kHz apart, covering a large, continuous block of spectrum)
from 14.195 to 21.45 MHz, including all or parts of the 20, 17 and 15-meter
amateur bands. Within those overall limits, the BPL signal was strong on
most frequencies, but there were some frequencies were the signal was fairly
weak.
The signals from 14.195 to 14.290 were weak, but plainly audible above the
ambient noise level. These are some of the "fringe" signals Mr Anthony
refers to in his April 20 e-mail. I monitored several amateur radio
transmissions in this spectrum, and while the signals did not obliterate
any, they did present an annoying, continuous tone behind all of them on my
single-sideband receiver.
The signals from 14.290 to 14.350, covering the top 60 kHz of the 20-meter
amateur radio band, were "full strength," reaching "S-7" on my Icom 706
MKIIG transceiver and Outbacker Perth Plus antenna while on the highway
adjacent to the power line. This is the same signal block I noted in my
March 29, 2004 complaint. I have also observed that signal block on April 6
(a demonstration with Bill Godwin), April 13, April 21, and April 29, in
addition to May 4 and May 19. It has not changed. It continues to be
strong enough to make reception of weak and moderately strong amateur radio
signals impossible.
The BPL signals continue full-strength through the 15.10-15.80 MHz and
17.50-17.90 MHz shortwave broadcast bands, and covered up some of the weaker
stations while putting an annoying, continuous whistle (heterodyne) against
some stronger signals.
The BPL signal does dip to just above the noise level in the 16.80 - 17.34
area. I believe this is the crossover area between downlink and uplink
signals on this leg of power line.
The signal is also weaker from 18.075 - 18.185. This is the notch for the
17-meter amateur radio band. However, the signal is full strength in the
bottom 7 kHz of the band, from 18.068, to 18.075. And the BPL signal
continues to be clearly readable, though weak, throughout the band. In
other words, the notch depth is not great enough to remove the signal
completely when it is "S-7" outside the notch. It remains strong enough to
obscure a weak ham signal, and presents a continuous, annoying heterodyne
behind stronger signals. It also presents the usual, continuous series of
carriers when tuning across unused frequencies while looking for stations to
contact.
I estimate that a home station would get an audible signal as far as two
blocks away. A ham on a lot within a half block of the line would get a
fairly strong signal. And this is the configuration I assume Progress
Energy would plan for the power lines in every neighborhood.
Inside the Holland Meadows neighborhood, where BPL is carried on
underground power lines, the signals are weaker than those on the overhead
lines. But they are still plainly audible and often much stronger than the
"fringe" and "notched" signals on the overhead lines in the vicinity of the
above-ground pedestals. At 1141 Feldman, I received signals from 2.5 MHz to
5.0 MHz, and from 5.95 MHz to about 9.7 MHz. This put full-strength signals
across the 80 and 40-meter ham bands. I estimate that a home station would
be able to hear these signals for a block or two as well. At 5528 Holland
Church Rd, I received signals from a pedestal from about 6.35 to above 8.3
MHz, including full strength signals across the entire 40-meter band.
At the Woodchase neighborhood, in Fuquay-Varina, I parked along James
Slaughter Road, just south of the entrance to the subdivision, on the west
side of the road. The total spectrum in use here ran from 21.20 to 28.1
MHz, with a notch for the 12-meter ham band, and a crossover around 25 MHz.
From 21.2 to 21.47 MHz, the signal slowly ramps up in amplitude, with
plainly audible signals in the 15-meter band from 21.35 to 21.45 MHz. At
21.47 MHz it jumps to full strength, interfering with a few shortwave
broadcast signals in the 21.45 21.75 MHz range. The BPL signals fall off
below the bottom of the 12-meter band, at 24.86, and remain weak to 25.20,
where they became inaudible. Once again, the BPL signals were weak but
audible throughout the entire 12-meter band. They fall off just below the
10-meter band at 28.0 MHz, but weak signals remain audible for another 100
kHz inside the ham band.
It would appear from the fact that the top 60 kHz of the 20-meter band and
the bottom 7 kHz of the 17-meter band still have full-strength BPL carriers
in them that this hardware is not that easy to control. The "fringe"
carriers, and the signals remaining in the notched segments, suggest that it
can't be just turned on and off where Progress Energy wants, at will, or
controlled to the level that they (and we) might desire.
Progress Energy has obviously paid attention to our complaints, and taken
steps to correct the problems that we've pointed out. Those steps have
fallen short, both by leaving full-strength signals on parts of two Amateur
Radio bands, and by leaving weak "fringe" or notched signals on other bands.
Rather than dispute our claims, I suggest Progress Energy take our
information to their vendor and ask why they can't make the hardware perform
to the level claimed.
We disagree on the definition of "harmful interference" a critical point
on which the FCC or a court will make the final determination. I can assure
you that the Amateur Radio and shortwave listening communities will work
hard to protect continued access to the radio spectrum without the
ever-present beat of a BPL signal in either the foreground or background of
our receivers.
Sincerely,
Gary Pearce KN4AQ
Gary Pearce KN4AQ, March 29, 2004 complaint, for reference
919-380-9944
Monday, March 29, 2004
This e-mail letter is a second formal complaint of interference received
from several Broadband over Power Line (BPL) installations operated by
Progress Energy in the Wake County, North Carolina area. This complaint
covers interference on NEW frequencies that was not present in my first
complaint filed on March 13th.
In my March 13th complaint I detailed interference that I observed while
operating my mobile amateur radio equipment in the vicinity of the Progress
Energy Phase II BPL trial areas in southern Wake County, North Carolina. No
one from either Progress Energy or the FCC has contacted me as a result of
that complaint (except a request from the FCC to drop David Solomon from the
recipient list, which I have done). I have seen Bill Godwin in a somewhat
chance encounter at the Holland Church site, and we had a good discussion on
the state of the trial.
I have observed that Progress Energy has changed the spectrum used for the
overhead line segments in both trial areas. If I'm correctly assuming that
this was done to respond to complaints, and demonstrate frequency agility
and the ability to mitigate interference by avoiding amateur radio spectrum,
the attempt is appreciated, but it was not completely successful. New
amateur radio and shortwave spectrum is now receiving interference, and that
is the basis of this complaint.
On March 20, 2004, in the Woodchase subdivision area near Fuquay-Varina,
where BPL signals had covered the 12 and 10 meter bands, I observed clear,
strong BPL signature signals from 21.5 to 24.90 MHz, and 25.49 to 28.0 MHz.
This almost cleared amateur radio spectrum, but not quite.
The lower segment, from 21.50 to 24.90 MHz, encroached clearly on the
bottom 10 kHz of the 12 meter band, from 24.89 to 24.90 MHz, and what I'll
call "residual" BPL carriers - carriers at the edge of the main spectrum
that trail off in amplitude over the course of 10 to 20 kHz - encroached
further. The residual carriers present a correspondingly decreasing problem
of interference, but when the bulk of the BPL carriers are strong, the
residual carriers can also interfere with weak amateur radio signals.
Note that if a BPL operator is attempting to place a BPL block adjacent to
the bottom of an amateur band, they should be aware that these residual
carriers will fall across an area of extreme interest where amateurs use
Morse code to communicate with distant, often very weak, amateurs in remote
parts of the globe. Additional care should be taken to avoid letting this
"residual" interference cross the bottom few kHz of any amateur band.
The higher segment, from 25.49 to 28.0 MHz, also left some residual
carriers encroaching on the bottom of the 10 meter band at 28 MHz. The main
carriers did cover all 40 CB channels and interfered with signals I
monitored there.
Then I drove through the Holland Church Road trial site and observed no
change since my March 13th complaint - the BPL signals still covered the 12
and 10 meter ham bands and adjacent spectrum.
On March 23, 2004, I returned to the Holland Church Road trial area.
That's when I ran into Bill Godwin and two other Progress Energy engineers,
observing and reporting on some difficulty that Amperion was having moving
the spectrum on the overhead line. The signals were gone from the 12 and 10
meter bands, and appeared erratically elsewhere. Since this was an effort
in progress, I didn't worry about the signals I received.
On March 28, 2004, I returned to the Holland Church site again. This time
I monitored signals on the following spectrum blocks:
14.29 - 16.805 MHz
17.33 - 21.00 MHz
24.53 - 28.00 MHz (with 12 meter notch?)
Reception was somewhat difficult because of a high general noise level
(what we usually refer to as "power line noise," ironically in this case.
The true source of this particular noise is unknown). The BPL signature
signals were generally strong and clear above this noise.
After observing what appeared to be an attempt to completely avoid amateur
radio spectrum at the Woodchase trial area, I was disappointed to see that
two busy amateur radio bands were partially or fully covered here: 20 and 17
meters. The BPL carriers interfered with many signals as I tuned from 14.29
to the band-edge of 14.35 MHz in the 20 meter band. Strong signals were
audible, but BPL carriers placed a loud "beat note" behind them, making
reception irritating at best. Weaker signals were rendered unreadable.
I had the same situation across the entire 17 meter band, from 18.068 to
18.168 MHz. Weaker signals were impossible to receive, while stronger ones
were accompanied by a loud heterodyne whistle.
I also tried listening to some shortwave broadcast signals in the spectrum
immediately above the 20 meter ham band. Switching to AM reception with a 6
kHz band pass filter, I noticed that the BPL signals were a continuos
"blanket" across the spectrum. Since the BPL carriers were 1.1 kHz apart, I
heard the expected 1.1 kHz heterodyne tone as part of that interference
blanket.
The 15 MHz signal from WWV was completely inaudible. Stronger shortwave
signals were audible with varying degrees of interference. Weaker signals
on 15.160, 15.205, 15.300, and 15.350 MHz were detectable but not readable.
This was just a brief sample of the many shortwave signals that received
interference from the BPL energy.
I could not observe any "residual" carriers spilling into the 15 meter ham
band as the "power line noise" made it difficult to hear the weakest BPL
carriers. With some difficulty I observed what appeared to be a notch in
the 24.53 - 28.0 MHz block. The carriers were at least attenuated in the
24.89 - 24.99 MHz area (the 12 meter ham band), but I thought I could hear
some weaker carriers through the "power line noise".
That is my report. I'll repeat my contention from my first complaint that
interference reports from mobile stations are warranted because:
- amateur radio is a very mobile radio service,
- these are very limited trial areas, and the experience and results must
be extrapolated to predict the effect BPL will have if widely deployed in
densely populated areas.
I'll conclude with an example of truly random interference caused by BPL
to a mobile ham who was not part of, or recruited by, our investigation
team:
Over the past few weeks I've had an e-mail exchange with Andy Stoy K4MTN,
from Wake Forest, NC. Initially, Andy's e-mail sounded like many that Tom
Brown N4TAB, Frank Lynch W4FAL and I have received from area hams who
suspect that they are hearing BPL interference from areas where none is
known to exist. Andy said he had been hearing loud interference - he called
it "static" - for months along a half-mile stretch of Falls of the Neuse
Road near the Woodfield subdivision. He was describing the Phase I trial
area which we believed to have been disconnected, and his description of
"static" didn't sound like the BPL signature we're used to.
I pressed him for more specific details, and he finally described the
exact location, and the signature sound (closer-spaced carriers with a
clicking sound) of Amperion's BPL. Tom Brown traveled to the site and
confirmed that the Phase I equipment was still operating on the overhead
line along Falls of the Neuse Rd. Andy traveled that route daily, and
regularly operates on the 10 meter band. He had been receiving interference
and loss of communications on that stretch of road since at least last
fall, but didn't know what caused the problem until we began publicizing the
trials. Then he contacted us. He will be filing his own report of
interference.
Andy's story may seem isolated, a rare, chance occurrence. It is
significant for several reasons. One is that it happened at all, since
there is a total of less than two miles of BPL coverage along Wake County
highways. Another is that hams don't know what BPL is yet. We've reached a
few with our message, but many more have never heard of it. So there may be
a few more Andy Stoy's out there who have passed through the existing trials
areas, received interference, and didn't know what it was or who to call.
I appreciate the fact that Progress Energy and Amperion are responding to
our reports and complaints of interference. I'd prefer to just call them
"reports," but public proclamations that "there have been no interference
complaints" have pushed us to this formal posture. My goal is to make you
(Progress Energy and the FCC) aware of the real conditions for radio
amateurs and other HF spectrum users in the trial area so that you can
anticipate the level of difficulty you can expect in a broader
implementation.
I'd expect that Progress Energy and Amperion could completely avoid
amateur radio spectrum in the overhead segments of this limited trial area.
I'm surprised that after the first complaints, you moved to occupy different
amateur radio spectrum. But even if you had completely missed ham bands in
this first move, success in this limited arena is not a good predictor of
the ability to mitigate interference in a full system, where you will be
constrained to use more spectrum and not re-use spectrum for several line
segments. And the question of interference from the underground line
segments has not been addressed at all.
Sincerely,
Gary Pearce KN4AQ
==============================================================
Gary Pearce KN4AQ's March 13, 2004 complaint, for reference
I encountered all of this interference while mobile, or visiting the
stations of other amateur radio operators. I do not hear any BPL
interference at my home in Cary at this time.
November 16, 2003. I first encountered BPL interference on this date,
near the Wakefield subdivision in north Raleigh, along Falls of the Neuse
Road near Wakefield Pines Rd. The interference appeared as a series of
closely spaced RF carriers, approximately 1 kHz apart, covering the lower
half of the 10 meter amateur radio band, from 28 to near 29 MHz (and some
spectrum below that band, including the 40 CB radio channels near 27 MHz).
Some of the carriers had a little "tik-tik-tik" sound at about a 2 Hz rate.
The interference was strong - S-9 - for about a half mile along Falls of the
Neuse Road, and obliterated several amateur radio signals that I was
monitoring.
I understand this was the Phase I trial area, and the test has been
discontinued.
January 15, 2004. On this and several subsequent dates, I received
interference while driving along Holland Church road between 1010 Road and
Pagan Rd. in southern Wake County, specifically in the vicinity of Feldman
Dr. The signature of the interference was the same: closely spaced
carriers, about 1 kHz apart, some with a tik-tik-tik modulation, and
occasionally a longer burst of what sounded like data. The interference
covered two blocks of spectrum, from 23.44 - 26.08 MHz (including the
amateur radio 12 meter band) and 27.9 - 31.7 MHz, (including the amateur
radio 10 meter band). The interference was strong - S-9 - for about a half
mile along Holland Church road, and audible in places along Pagan Rd. It
obliterated several amateur radio signals that I was monitoring as I drove
through the area.
I also received interference with the same signature in several spots
along Feldman Dr., in various other segments of the high-frequency
spectrum - near 11 and 15 MHz in particular. The signals were weaker, but
plainly audible. Onc caused a "beat note" against the 15 MHz WWV time and
frequency reference signal.
I have subsequently been through this area several times, and the
interference is still present. My last visit was on February 28th.
February 20, 2004. On this and several subsequent dates, I received
interference while driving along NC Highway 55 and James Slaughter Rd, just
north of the town of Fuquay-Varina. The interference was strongest along
James Slaughter Road, opposite the Woodchase subdivision. Again, the
signature of the interference was RF carriers, about 1 kHz apart, with a bit
of digital modulation now and then, including the tik-tik-tik at about a 2
Hz rate.
This interference was across 21.9-25.7 MHz (including the amateur radio 12
meter band) and 27.5-30.0 MHz (including the amateur radio 10 meter band).
The interference was S-9 along James Slaughter Road, and S-5 in the Food
Lion parking lot at NC-55, and obliterated several amateur radio signals
that I was monitoring.
In the Woodchase subdivision, I also heard the "BPL signature" signals on
several other points in the high frequency spectrum. The signals were
weaker, but plainly audible. I also heard signals in the 7 and 24.5 MHz
area about a mile further north on James Slaughter Road, near the Whitehurst
subdivision. These signals were S-6 to S-9 for about 1/4 mile along James
Slaughter Road.
I most recently heard this interference on March 5th, 2004.
Finally, on February 28, 2004, I personally visited the homes of three
amateur radio operators who live in the vicinity of the Progress Energy
Phase II BPL trials, and observed interference as received at their stations
as follows:
Mike Payne KM4UT
5813 HEATHILL CT
Raleigh, NC
Mile lives .7 miles south of the trial site on Holland Church Road. He is
using a dipole antenna at about 30 feet. I observed that he was receiving a
clear but weak BPL "signature" in the top half of the 10 meter band, above
28.8 MHz, and many smaller clusters of individual carriers in the band below
that.
Ted Root N1UJ
509 WYNDHAM DR
Fuquay-Varina, NC
Ted is about a half mile southwest of the James Slaughter Road site. He
is also using a dipole antenna at about 40 feet. He was receiving weak but
clear BPL signature signals across the 25 and 28 MHz areas.
Roland Erickson WA0AFW
201 WILBON ROAD 301B
Fuquay-Varina, NC
Roland is about a half mile south of the James Slaughter Rd. site. He is
using a dipole antenna in the attic of a retirement village building. He
has a very high ambient noise level (S-6) across the 25 and 28 MHz bands,
but was receiving the BPL signature signals clearly above that noise level
across those bands.
You might ask if my complaint of interference while mobile, some distance
from my home, is justified. I contend that it is, for several reasons.
First, amateur radio is a very "mobile" service. Tens of thousands of ama
teur radio operators have and use high frequency mobile equipment, and we
can be found anywhere, using all hf bands, at completely unpredictable
times.
Second, the Progress Energy Phase II trials are in very limited area
tests. There are no amateur radio operators living inside the neighborhoods
being served, though there are several within interference range - about a
mile. We are justified in traveling to the sites with normal amateur radio
equipment, operated in a normal manner, to observe and complain about
interference we receive. This observation must be extrapolated to a wider
geographic area to anticipate the kind of interference that would be
received if BPL were to be widely deployed, especially in denser suburban
and urban neighborhoods.
You might also ask if weak BPL signals constitute harmful interference. I
contend that they do. Amateur radio operation is unlike most other radio
operation, in that amateurs tune across their band segments looking for
signals. Often we are looking for weak signals from distant parts of the
world. Our predominant modes are single sideband and cw. In those modes, a
series of carriers 1 kHz apart presents a most irritating series of "beat
notes" - tones that vary in pitch as the spectrum is tuned. At 1 kHz
spacing, they are continuously present in a receiver using customary
bandwidth filters. And even weak BPL signals can make weak amateur radio
signals difficult or impossible to receive.
The presence of any BPL signal of any strength at either a home or mobile
station at any location is an unwarranted incursion in the amateur radio
bands, and is also a problem for anyone tuning shortwave broadcast or other
radio services.
Thanks for your consideration. I look forward to hearing the results of
the investigation into my complaints.
Sincerely,
Gary Pearce KN4AQ
__________________________________________________________________________
Gary Pearce KN4AQ editor, SERA Repeater Journal
Cary, NC www.sera.org
919-380-9944 kn4aq at sera.org
kn4aq at arrl.net
AOL/Yahoo Instant Messanger: KN4AQ
(send e-mail to be put on my "buddy list")
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