[NCham] Re: Questions about BPL, Hams and SWLs, and an Action Plan

[Gary Pearce KN4AQ]

QUESTIONS ABOUT BPL, HAMS AND SWLS, AND AN ACITON PLAN

Wayne Blackwell KD4SLQ sent me some questions following my talk about BPL=20
at the SWL meeting last night.   Good questions, and I thought I'd share my=
=20
answers.  Farther below, I list several steps to take concrete action.

Plan on spending the better part of a day with the Action Plan.  You won't=
=20
get through this in 20 minutes.

At 01:11 AM 4/20/2004, wayne blackwell wrote:

>What about emergency services ?  Did I detect a  "don't worry about that"=
 ??

Not quite, but I said don't focus too much on that.  Here's how it breaks=
 down:

Having BPL covering the frequencies used at either end of a communications=
=20
path would be a problem for hams handling emergency communications.  But=20
BPL's biggest impact will be on routine, everyday operation.  You turn on=20
your radio one day and find that RF from a local power line is obliterating=
=20
a couple of ham or SW bands.  How much of a hassle will you have getting it=
=20
cleared up, IF the utility can clear it up, on all bands?  And you listen=20
to literally the entire HF spectrum at one time or another.  How much=20
should you give up?

It's tempting to raise the alarm over emergency services frequencies, even=
=20
though the operators of those services are pretty quiet (APCO and FEMA did=
=20
file negative comments for the NOI, but FEMA has somewhat backed off).

Here's why that won't work: BPL technology can fairly easily notch spot=20
frequencies.  They can actually notch whole ham bands - 100 kHz or more=20
wide - but if they go below a total of 6 MHz of spectrum they lose=20
throughput.  So FEMA, aviation, hurricane watch, highway patrol, etc., can=
=20
all get notches for their channels.  Claiming that BPL will interfere with=
=20
those services just gives the BPL industry the opportunity to tout their=20
agility.  Your argument is squelched.

There might be some limited mileage in worrying about their ability to "get=
=20
it right" when adjusting the system to avoid causing interference, but I=20
think we should express that only in connection with the utilities ability=
=20
to make things right for US, not for others.

BPL most seriously affects people who use relatively wide swaths of=20
spectrum, just the way BPL covers wide swaths of spectrum.  People who tune=
=20
the band looking for sometimes weak signals will have the biggest problems,=
=20
and the utilities will have the hardest time clearing all the spectrum they=
=20
use.

>Is  NC  SHP  42.xxx  above the BPL "band"  ???
>Is Salvation Army  35.940  above  BPL ???
>Salvation Army Team Emergency Radio, SATERN, is 3950.0  HF  LSB

The spectrum most often cited in general is "2 to 80 MHz."  Amperion says=20
their system can go up to 50 MHz.  I've seen it as low as 3 MHz, and as=20
high as about 31 MHz so far.

>Isn't there a part of FCC rules which says that, in an emergency, Hams MAY=
=20
>use whatever freq they CAN use (e.g. SW bands & PLC & FEMA freqs) ???


=A797.403 Safety of life and protection of property.

      No provision of these rules prevents the use by an
      amateur station of any means of radiocommunication
      at its disposal to provide essential communication
      needs in connection with the immediate safety of
      human life and immediate protection of property
      when normal communication systems are not available.

But I'm not sure what you'd be saying about it.  "Don't put BPL anywhere=20
because I may need any frequency some day in an emergency"?  You'd spend a=
=20
lot of time trying to explain yourself.  Maybe you had something else in=
 mind.

THE BOTTOM LINE:
The BPL industry is moving away from their initial claim that "there is no=
=20
interference" to say instead that they have the agility and ability to=20
clear up any problems that do occur (as would be required by the Part 15=20
NPRM).

That leaves us saying (if anyone will listen), "Oh no you don't," and=20
having to explain in terms more technical than the average person can=20
understand:

- That we listen literally everywhere, so where can they put BPL around our=
=20
house that won't interfere?

- And we don't think they have the ability to keep the ham bands and SW=20
Broadcast bands clear, assuming that it's OK cover other spectrum.

5-STEP ACTION PLAN

1. Go to the ARRL web site (www.arrl.org) and read the two articles there:
-- "It Seems to Us..." BPL: What Now?
-- ARRL Encouraging "Thoughtful, Considered" Comments on Proposed BPL Rules

Links to all the ARRL articles on BPL, including several on our activity=20
here in the Raleigh area, are collected at:
http://www.arrl.org/tis/info/HTML/plc/#Amateur_Radio_Articles

2. Download and read the NPRM:
http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=3Dpdf&id_docum=
ent=3D6515783486

3. Send your comments by May 3rd (I have a step-by-step on doing that,=
 below).

4. Let Progress Energy know that you are a ham or SWL who will be affected=
=20
if power lines in your area carry BPL RF, and if that happens you will=20
complain and require mitigation.

Progress Energy had heard from a lot of hams, many very angry, since last=20
summer when word of their BPL trials first started to spread.  They reacted=
=20
by contacting Tom N4TAB, Frank W4FAL and me to act as a "point of contact"=
=20
between them and the ham community, because there was no way they could=20
talk to all the hams at once.  So the goal is not to start that process all=
=20
over again.  The goal is to get them to realize that they just might be=20
biting off more than they want.

So make the contact simple.  Say, "I'm here.  I listen to/use wide segments=
=20
of the high frequency shortwave radio spectrum.  If BPL appears on power=20
lines within a half-mile of my home, it will affect me, and I will=20
complain.  Please consider this as you decide whether or not to go forward."

Their "Contact us" page is:
http://www.progress-energy.com/shared/contactus/index.asp

5. Contact legislators, the NC utility commission, and anyone else you=20
think might be able to help.  Note that there is no legislation involved,=20
and this is an "unregulated" part of Progress Energy's business, not under=
=20
control of the utility commission.  But legislators and commissioners are=20
interested, and can ask questions that require answers.

Don't say "BPL will cause interference to critical emergency services." The=
=20
industry can counter that claim easily, as I explained above, with=20
frequency agility and notches.

Say that BPL emits radio signals from the power lines that cover wide areas=
=20
of the shortwave radio spectrum, interfering with reception a half-mile or=
=20
more from power lines.  Note that it is legal and, for many, interesting to=
=20
listen to any and all shortwave frequencies, including monitoring Shortwave=
=20
Broadcast, aviation, emergency services, amateur radio, CB radio, and any=20
government and military communications that are transmitted "in the clear."

Say you understand that Progress Energy claims that they can clear up=20
interference, but note that they have not said how they would do it.  Their=
=20
signals must go somewhere in the radio spectrum, and anywhere they go, they=
=20
will interfere with something for someone, since they travel so far from=20
the power line.

73,
Gary KN4AQ


=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=
=3D=3D

HOW TO FILE COMMENTS ON THE PART 15 NPRM

Here are instructions for filing simple, brief comments, and additional=20
instructions for filing more extensive comments.  It'd say "it's easy," but=
=20
I hate it when people say that.  However, it is......

SIMPLE COMMENTS

On the main FCC web page (www.fcc.gov), look down the left hand column for=
=20
a headline that says:

"Filing Public Comments"
ECFS Express
main | alternate

Click on "main"

There, you will find a list of dockets currently open for public=20
comment.  At the top of the list (as I look at it today) is:

- Broadband Over Power Line (BPL) - Docket 04-37

Select that and click "continue" at the bottom of the page.

That takes you to a form to fill our your name, address, e-mail (this is=20
not eHam - no anonymous comments), and room to type in a "Brief=20
Comment."  You probably want to write your comment in Word or something=20
with grammar and spell checking first, then cut and paste it into the=20
box.  Don't use any text formatting like bold or italics.  They'll be=20
lost.  If you want to do that, go to the more EXTENSIVE comments section,=20
below.

Read your comments over once you've written them.  From many of the=20
comments I've seen, I must assume that some hams don't read what they wrote=
=20
before they click "send".

When you've finished that, click "Send Comments", and you're done.


EXTENSIVE COMMENTS

First, you might want to look over comments that have been filed already.

Go to the main ECFS page:
http://www.fcc.gov/cgb/ecfs/
and on the right, select "Search for Filed Comments"

Enter 04-37 in the "Proceeding" box (that's all you need to fill out), and=
=20
click "Retrieve Document List" (or just hit ENTER).  You'll see the first=20
10 of a long list (309 comments have been filed as of today).  You can be=20
pickier about what to look for if you know who filed comments, or when, by=
=20
filling in more boxes.

Click on the highlighted link in any box (most say "Comment," but there are=
=20
a variety of options you can file.  The ARRL has a MOTION FOR EXTENSION OF=
=20
TIME filed on 4/9/04).  Your browser will download the posting in Adobe=20
Acrobat form.  You'll need Acrobat Reader on your computer.  If you don't=20
have that, get it from www.adobe.com. It's free.  If you don't know=20
anything about Acrobat Reader, I'm afraid you're a bit over your head here.

Now, compose your own comments.  You should use a program file format you=20
can upload.  The site accepts Adobe Acrobat PDF, Microsoft Word and Excel,=
=20
Word Perfect, Lotus 123, and ASCII text.  You can polish it all you want,=20
and use the formal header with all the )))'s in it if you like.  I don't=20
know if there's any extra credit for that.  Bold, italics and other=20
formatting are OK.  Don't use fancy fonts - they will probably be lost, and=
=20
a bad substitute will replace them.  Save your file where you can find it -=
=20
you'll be navigating to it later.

Then go back to the ECFS page http://www.fcc.gov/cgb/ecfs/
and select Submit a Filing .

Enter 04-37 in the "Proceeding" box, and fill out your name and address (if=
=20
you want your callsign to show, add it in the "Name" box - there's no=20
special place for callsigns).

At the bottom of that form is a drop-down box where you can select the kind=
=20
of submission you'll be filing.  "COMMENT" is probably the right one.

Below the box for your name and address is another box that says
"Send Comment Files to FCC (Attachments)"

There is a drop down box here to select the file format you'll be=20
uploading, so select that.  Then click in the "Browse" box, and navigate=20
through your computer to the file you prepared.  Hey, I told you to put it=
=20
where you could find it, so don't complain to me that you can't.

Once you've selected the file, click "Send Attached File to FCC", and away=
=20
it goes.  It will be converted to Acrobat PDF and added to the list of=20
filed comments.

Congratulations!

Tomorrow, or maybe later today if it's not a weekend or holiday, go back=20
and look at the filed comments, and there you'll be, in all your glory!

Geez, you'll think, my comment is just buried there among all the (other)=20
illiterate jerks who filed on this docket!  Can't they put a star or=20
something by mine to make it stand out?

If you find a way, let me know.



__________________________________________________________________________
        Gary Pearce KN4AQ        editor, SERA Repeater Journal
        Cary, NC                 www.sera.org
        919-380-9944             kn4aq@sera.org
        kn4aq@arrl.net
         AOL/Yahoo Instant Messanger: KN4AQ
         (send e-mail to be put on my "buddy list")