[KYHAM] Fwd: NASB views of BPL

[Bill Fuqua]

>X-Auth-No:
>From: Radiomiami9@cs.com
>Date: Sat, 28 Jun 2003 15:14:23 EDT
>Subject: NASB views of BPL
>To: wlfuqu00@uky.edu
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>
>Dear Bill:
>
>Our Secretary/Treasurer. Dan Elyea, has passed your message on to me.  As=
=20
>Dan mentioned, we are very concerned about the BPL issue.  Following is a=
=20
>copy of a letter which we recently sent to radio hobby magazines in the=
 U.S.:
>
>-------------------------------
>
>National Association of Shortwave Broadcasters
>10400 NW 240th Street
>Okeechobee, FL 34972 USA
>
>May 8, 2003
>
>Dear Shortwave Listening Colleagues:
>
>We wish to inform you and your readers of a potentially disastrous Notice=
 of
>Inquiry (NOI) currently being undertaken by the Federal Communications
>Commission. This NOI deals with Broadband Internet Service over Power=
 Lines,
>or BPL. The Press Release for this NOI can be found at the following URL:
>
>http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-A1.doc.
>
>The actual NOI can be found at this URL:
>
>http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-100A1.doc.
>
>This BPL system will operate by injecting a broadband signal on power lines
>within a person=E2=80=99s home in the frequency ranges of 2-30 MHz. These=
 are
>broad-spectrum signals that will effectively make the wiring in a=
 person=E2=80=99s
>home a noise generator throughout the HF broadcast spectrum. Noise from
>power lines is bad enough as it is - adding this to the existing background
>noise could make the HF bands totally useless from a listener's standpoint.
>
>Similar systems are being implemented in Europe, with disastrous results=
 (See
>http://www.powerline-plc.info/video). Japan last year totally rejected BPL
>as a method of Internet distribution because of its disastrous effects on=
 the
>HF bands.
>
>I would urge your readers to research these sites, and write to the FCC in
>response to this NOI. Make the FCC aware that there are shortwave
>enthusiasts in the United States that are opposed to any system that would
>further degrade the quality of their hobby - shortwave listening.
>
>When writing a response, an original and four copies should be sent to:
>
>Commissioner=E2=80=99s Secretary
>Office of the Secretary
>Federal Communications Commission
>445 12th Street, SW
>Washington, D.C. 20554
>
>If possible, responses should be received by the FCC by June 13, 2003.
>
>Thank you for allowing us to make this issue known to all shortwave
>enthusiasts.
>
>Sincerely,
>
>
>Jeff White, President
>National Association of Shortwave Broadcasters
>E-mail: radiomiami9@cs.com
>
>----------------------------------
>
>The NASB is also expressing its views to the FCC on the BPL=20
>issue.  Following is a draft copy of our official comments on the Notice=20
>of Inquiry:
>
>NASB Response to NOI on BPL
>
>May 16, 2003
>
>The National Association of Shortwave Broadcasters has prepared this=20
>response to the FCC NOI (FCC-030100).  The NASB represents 17 of the=20
>FCC-licensed privately owned shortwave broadcasters located in the United=
=20
>States.
>
>The FCC has requested information and data regarding a variety of issues=20
>related to Broadband over Power Lines systems, or BPL.  The FCC is=20
>considering changes to Part 15 of the Commission=E2=80=99s rules in order=
 to=20
>facilitate the deployment of this technology.  We feel very strongly that=
=20
>the FCC should consider stiffening and strengthening the Part 15 rules,=20
>and not ease them, as we view BPL as a dangerous technology that will=20
>disrupt and interfere with the many radio applications now in use in the=20
>bands between 2 and 30 MHz.
>
>We believe that the adoption of a BPL system in the United States, using=20
>wide spectrum techniques from 4.5 mHz to 21 MHz would result in de facto=20
>=E2=80=9Cjamming=E2=80=9D of international shortwave broadcasts intended=
 for listeners=20
>in the United States, and would be a violation of the First Amendment of=20
>The Constitution of the United States.  Additionally, the FCC, as the=20
>regulatory body for the United States, is mandated by treaty within the=20
>ITU to protect the reception of radio broadcasts from abroad, and to limit=
=20
>or remove any sources of interference with such reception.  Further, we=20
>fully believe that this system would result in harmful interference to=20
>authorized domestic operations that include fixed, land mobile,=20
>aeronautical mobile, maritime mobile, radiolocation, broadcast radio,=20
>amateur radio terrestrial and satellite, and radio astronomy.
>
>We feel Commissioners Copps and Adelstein are wise to express concerns=20
>about BPL interference to other licensed radio spectrum users in these=20
>bands.  We would like to thank them for their well-founded concerns, and=20
>hope that the other Commissioners will also come to realize that BPL is a=
=20
>dangerous technology that should not be implemented or encouraged.
>
>Many of the authorized services noted above play an important role in=20
>Homeland Security, and would be severely compromised by interference from=
=20
>BPL.  These services currently provide reliable and proven methods of=20
>communication when other means of communication have been disrupted.  It=20
>would be extremely unwise to introduce any new source of potential=20
>interference that might have an adverse affect on these communications.
>
>The FCC is considering two different BPL technologies - Access and=20
>In-House.  Both systems would employ multiple carrier signals spread over=
=20
>a broad range of frequencies.  The conducted energy from a BPL system can=
=20
>cause harmful interference to radio communications via two possible=20
>paths.  First, the RF energy is carried through the electrical wiring to=20
>radio receivers connected to the electrical wiring.  Second, at=20
>frequencies below 30 MHz, where wavelengths exceed 10 meters, long=20
>stretches of  power line wiring will act as an antenna, permitting the BPL=
=20
>RF energy to be radiated over the airwaves.  In this case, it would have=20
>the effect of raising the already high noise floors for radio=20
>reception.  And as there is relatively low propagation loss at these=20
>frequencies, such radiated energy would cause harmful interference to=20
>portable or mobile radio receivers, even those at a considerable distance=
=20
>from the power lines.  This effect would be quite noticeable in both urban=
=20
>and rural settings.  And such a system would be imposed on everyone served=
=20
>by the power line, whether they wish to receive the service or not.
>
>The NASB believes that it will be impractical, if not impossible, to=20
>develop  a standardized measurement technique to ensure compliance at any=
=20
>protection level that the Commission may adopt.  These BPL systems will=20
>use electrical wiring within a building as the means to transmit=20
>data.  Thus the impedance of the building system will change every time a=
=20
>device or appliance is added, removed, or turned off or on.  Such an=20
>widely changing environment would make modeling of the system impractical=
=20
>if not impossible.  The radiated emissions from the RF energy imposed on=20
>the building=E2=80=99s electrical wiring would vary from location to=
 location,=20
>based on the wiring of each building and the building=E2=80=99s power=20
>requirements.  And as the building wiring would also serve as an antenna,=
=20
>then that wiring structure would also have to be accounted for in any=20
>evaluation methodology.  Certainly, measurements made in any laboratory=20
>setting would not be valid, as each system would be a unique set of=20
>parameters to be measured and evaluated.
>
>There is some very clear history to demonstrate the harmful affects of BPL=
=20
>services on radio reception.  These have been observed in Europe and=20
>Japan; and, in Japan, the decision was made in 2002 to disallow BPL as a=20
>suitable system for data transmission.  The measured effect of=20
>interference in test cases there, plus a study conducted by Professor=20
>Filippo Giannetti of the University of Pisa, convinced the Japanese=20
>authorities to reject BPL as an acceptable system.  Also, we would invite=
=20
>the Commission to investigate the concerns being raised in Europe=20
>regarding the unhappy affects of BPL on radio communications there.  DRM,=
=20
>the leading digital methodology for the future of radio, has expressed=20
>strong concerns, as has the European DX Council, the Radio Society of=20
>Great Britain and the Austrian Amateur Radio Society.  The latter has=20
>established a web page with quite a number of examples of interference=20
>caused by these BPL systems being introduced in Austria=20
>(http://www.powerline-plc.info/video).  Also, the Radio Society of Great=20
>Britain has a web page with its concerns regarding BPL implementation=20
>(http://www.rsgb.org/emc/pltnew.htm).  Finally, an English translation of=
=20
>Professor=E2=80=99s Giannetti=E2=80=99s study can be found at the EDXC web=
 site=20
>http://www.edxc.org/modules.php?op=3Dmodload&name=3DSections&file=3Dindex&r=
eq=3Dviewarticle&artid=3D1&page=3D1.
>
>The European Broadcast Union has also developed a proposal on BPL systems=
=20
>and their emissions.  This EBU proposal was first presented as a report to=
=20
>the DRM membership and can be found at=20
>http://www.bbc.co.uk/rd/pubs/whp/whp013.html.  It was developed by=20
>Jonathon Stott of the BBC Research and Development Group.  The BBC and its=
=20
>broadcasting arm, VT Merlin, are very pro-active in their objection to any=
=20
>relaxation of interference mediums to the broadcast bands, and this report=
=20
>clearly demonstrates that BPL systems are a serious threat to broadcasting.
>
>The NASB feels that BPL systems should be required to demonstrate, and the=
=20
>FCC should certify that the magnetic field of the emissions should be 0=20
>dBu V/m, measured at a distance of one meter, in a bandwidth of 9 kHz, and=
=20
>utilizing a peak detector.  This is the only good methodology that can=20
>guarantee that the BPL system will not contribute harmfully to the radio=20
>spectrum from 2 to 30 MHz.
>
>In conclusion, the NASB feels that BPL systems will jeopardize the current=
=20
>use of the radio bands between  2 and 30 MHz.  While the FCC may see a=20
>need to develop new and faster broadband Internet access for the United=20
>States, BPL is certainly not the answer.  The problems created by BPL for=
=20
>existing radio services and users will far outweigh any benefits that can=
=20
>be envisioned for the general populace.  We would urge the FCC to strongly=
=20
>reconsider the development of BPL systems.
>
>--------------------------------------
>
>Thank you very much for your comments on this issue, Bill, and we urge you=
=20
>to write the FCC as well.
>
>Sincerely,
>
>Jeff White
>President, NASB
>radiomiami9@cs.com


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