[TNham] FEMA to FCC: BPL will "Severely Impair" Mission-Essential HF Operations

[Kenny Breeding]

http://www2.arrl.org/news/stories/2003/12/08/1/?nc=1
FEMA to FCC: BPL will "Severely Impair" Mission-Essential HF Operations
NEWINGTON, CT, Dec 8, 2003--Expressing "grave concerns" about likely
interference from unlicensed Broadband over Power Line (BPL) systems, the
Federal Emergency Management Agency (FEMA) has told the FCC that BPL could
"severely impair FEMA's mission-essential HF radio operations in areas
serviced by BPL technology." FEMA filed comments December 4 in response to
last April's FCC BPL Notice of Inquiry, ET Docket 03-104. FEMA expressed
primary concern over BPL's potential impact on the FEMA National Radio
System (FNARS), which operates on HF and serves as the agency's primary
command and control backup medium as part of the Federal Response Plan.

"FEMA has concluded that introduction of unwanted interference from the
implementation of BPL technology into the high frequency radio spectrum will
result in significant detriment to the operation of FEMA radio systems such
as FNARS," FEMA's comments assert. "FNARS radio operators normally conduct
communications with signals that are barely above the ambient noise levels."
FEMA further noted that FNARS HF stations typically are in residential areas
of the sort that BPL--a form of power line carrier (PLC) technology--might
serve.

BPL also could render such "essential communications services" as the Radio
Amateur Civil Emergency Service (RACES), the Military Affiliate Radio System
(MARS) and the Civil Air Patrol (CAP) useless, FEMA said. FEMA and ARRL last
year signed a Memorandum of Understanding that focuses on how Amateur Radio
personnel may coordinate with the agency to support emergency communications
functions.

Calling the HF spectrum "an invaluable and irreplaceable public safety
resource," FEMA said there's no current alternative to HF in terms of
meeting national security and emergency preparedness requirements at the
national, state and local levels. The agency recommended beefing up the
FCC's Part 15 rules to ensure no increase in interference levels to existing
FCC or NTIA-licensed communication systems, "because any noise increase
inevitably would diminish the ability to maintain essential communications,"
FEMA said, and would "directly impair the safety of life and property."

The BPL interference situation is reciprocal, FEMA noted, citing
"Interference to PLC systems from Amateur Radio Operation". That paper
points out that Amateur Radio transmitters likely would interfere with BPL
systems. BPL users likewise would experience service interruptions when its
transmitters "overpower the signal levels expected by BPL modems," FEMA
predicted.


FCC adoption of proposals to encourage widespread development and deployment
of BPL also could result in consumer confusion regarding who would resolve
interference issues and how. FEMA said it believes licensed radio services
"will be perceived by consumers as responsible for the interference, since
most consumers do not understand that their unlicensed Part 15 devices 'must
accept any interference received, including interference that may cause
undesired operation.'"

"The purported benefits of BPL in terms of expanded services in certain
communications sectors do not appear to outweigh the benefit to the overall
public of HF radio capability as presently used by government, broadcasting
and public safety users," FEMA concluded.

FEMA Chief Information Officer Barry C. West, who filed the comments on the
agency's behalf, characterized the issues it raises as being "of great
importance to the national public safety." Because FEMA now is part of the
Department of Homeland Security, its perspectives on BPL could carry
substantial weight at the FCC, which may issue a Notice of Proposed Rule
Making as early as February.

The ARRL announced last week that it plans to complete an independent BPL
engineering study within a couple of months. The study will explore how BPL
might affect HF and low-VHF amateur operation as well as how Amateur Radio
operation could affect BPL systems.





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