[Paham] FCC PROPOSES RULES FOR BPL SYSTEMS

[WORKSNTV@aol.com]

The FCC this week released its Notice of Proposed Rule Making (NPRM) on
Broadband over Power Line (BPL) systems. The 38-page NPRM--in ET Dockets
03-104 and 04-37--proposes amendments to FCC Part 15 rules to define
so-called "access BPL," make rules specific to BPL systems and provide
measurement guidelines for BPL devices and systems. It would make no
changes to Part 15 emission limits for unintentional radiators, however.
ARRL CEO David Sumner, K1ZZ, says that while Part 15's current limits on
unintentional radiators on HF may be appropriate for short-duration,
narrowband emissions, they are inappropriate for the sort of
long-duration, broadband emissions BPL would employ. He compared
short-duration, narrowband emissions at the Part 15 radiated emission
limit to a helicopter flying overhead.

"The noise is deafening, but is tolerable because it doesn't happen very
often nor last very long," he observed. "To a radio user, having BPL in
the neighborhood would be like having the helicopter hovering constantly
overhead."

ARRL Lab Manager Ed Hare, W1RFI, offered an example most hams could relate
to. "The limit for an unintentional emitter on HF is 30 uV/m at 30 meters
from the source," he said. "If you take a dipole cut for 3.5 MHz and put
it in a 30 uV/m field, you'll have a noise reading of S9 plus 16 dB at
your transceiver."

The FCC proposal takes a broader view of interference. "There is
significant disagreement among the commenting parties regarding the
interference potential of Access BPL," the NPRM declares. "Amateur
operators and amateur organizations in general are opposed to Access BPL
and advocate emission limits that are lower than the existing Part 15
limits."

Still, the NPRM concedes, Amateur Radio operations "are likely to present
a difficult challenge in the deployment of Access BPL in cases where
amateurs use high-gain outdoor antennas that are located near power
lines." Noting that power line noise already presents a significant
problem for hams, the FCC said, "we therefore would expect that, in
practice, many amateurs already orient their antennas to minimize the
reception of emissions from nearby electric power lines."

The NPRM goes on to point out that because BPL has the capability to stay
clear of specific frequencies, BPL providers can simply "avoid the use of
amateur frequencies when in close proximity to amateur outdoor antennas."
The NPRM also briefly mentions the possibility of interference to BPL
systems from Amateur Radio, an issue ARRL and others raised in their
comments on last April's Notice of Inquiry on BPL.

The NPRM emphasizes that under the proposed rules, operators of Access BPL
systems would be responsible for eliminating any harmful interference that
may occur. The FCC says it believes current Part 15 emission limits for
carrier current systems--in conjunction with certain additional
requirements specific to Access BPL--"will be adequate to ensure that
existing radio operations are protected against harmful interference."

Sumner suggested that, with licensed services and government users taking
up large portions of the HF spectrum, protecting all licensed HF users
could prove to be a nightmare for BPL providers. He noted, too, that while
the FCC maintains that licensed services must be protected, the proposed
rules place the burden of initiating corrective action on the shoulders of
the licensed services. "And as a practical matter, the FCC's proposed
rules offer no protection at all to mobile and portable stations," he
added.

Sumner also said the ARRL would continue to combat the "misconception"
that BPL systems are viable as a "last mile" broadband technology for
rural dwellers. "In low-density areas, the economics just don't work," he
said.

The NPRM is available on the FCC Web site in Microsoft Word format
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-29A1.doc> or as
an Adobe PDF file
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-29A1.pdf>.

Interested parties may file detailed comments on the NPRM via the main
FCC's Electronic Comment Filing System (ECFS)
<http://www.fcc.gov/cgb/ecfs/>. The comment deadline is 45 days after the
NPRM has been published in The Federal Register, and that is not expected
to happen for another week or two. The FCC also is accepting brief
comments on the NPRM via its ECFS Express page
<http://gullfoss2.fcc.gov/ecfs/Upload/>.

Additional information about BPL and Amateur Radio is on the ARRL Web site
<http://www.arrl.org/tis/info/HTML/plc/>. To support the League's efforts
in this area, visit the ARRL's secure BPL Web site
<https://www.arrl.org/forms/development/donations/bpl/>.