[Swprograms] BPL NPRM Comment Period

[Joe Buch <joseph.buch@xxxxxxx>]

>From today's ARRL Letter:

==>ARRL URGES "THOUGHTFUL, CONSIDERED COMMENTS" ON PROPOSED BPL RULES

Comments on the FCC Broadband over Power Line (BPL) Notice of Proposed
Rule Making (NPRM) in ET Dockets 03-104 and 04-37 are due by Monday, May
3. The deadline for reply comments--comments on comments filed by
others--is Tuesday, June 1. The ARRL will comment by the deadline on the
FCC's proposals to amend its Part 15 rules to adopt new requirements and
measurement guidelines for so-called "Access BPL" systems that provide
broadband access via electric utility power lines. ARRL CEO David Sumner,
K1ZZ, says the League recommends that members read the NPRM and develop
their own thoughtful, considered comments that specifically address the
FCC's BPL proposals, reflect positively on the amateur community and, if
possible, offer alternative recommendations. He asked amateurs to keep
four things in mind, however.

"First, this is not a proceeding to 'permit' or 'authorize' BPL," he said.
"BPL is already permitted under the existing Part 15 rules."

Second, Sumner pointed out, the NPRM reaffirms that licensed services must
be protected from harmful interference and are not required to protect BPL
systems. "This is good, but we can't take it for granted that the
principle will be honored in practice," he said.

"Third," Sumner went on, "the NPRM proposes additional, new constraints on
BPL to protect licensed services. The FCC did not go far enough, but at
least the proposals aim in the right direction."

Finally, while the League continues to believe firmly that BPL is "a very
bad idea," arguing that the FCC should ban BPL "will not get us anywhere,"
he concluded. Instead, Sumner says, amateurs must document beyond any
doubt the levels of protection that must be given to over-the-air
services, then leave it for others to decide whether BPL is feasible
within those limits. "We need to prove that the risk of interference is
significantly greater than the BPL proponents say it is," Sumner said.

He also asserted that the FCC's proposed "interference mitigation"
requirements fall far short of providing real protection from harmful
interference, and that the Commission is ignoring the practical problems
that will arise when Amateur Radio transmissions disrupt BPL systems.

Carrier current systems like BPL are subject to the FCC's Part 15 rules
governing unlicensed devices, and the FCC has acknowledged that "amateur
operations are likely to present a difficult challenge" to BPL deployment,
especially in the case of hams--an estimated 150,000 of them--who use
high-gain antennas sited near power lines. The proposed rules remain
silent on the issue of mitigating BPL interference to the estimated 70,000
Amateur Radio HF mobile stations.

Interference mitigation for mobile stations "is clearly impractical,"
Sumner asserted. "Since BPL systems operating at the present Part 15 limit
cause harmful interference to mobiles, the only solution is an absolute
limit on radiated emissions that is lower than the present limit." He said
the ARRL was in the process of determining scientifically what the limit
must be.

Sumner further noted that the NPRM does not mandate a publicly accessible
BPL database to facilitate interference mitigation for fixed stations. In
addition, the League wants the FCC to establish performance standards for
BPL interference mitigation. "There must be severe enforcement penalties
for failure to resolve a complaint in real time and for failure to
maintain the database," he said.

The League encourages anyone, particularly radio amateurs, who has
actually experienced BPL interference to file detailed comments
documenting the interference. "BPL proponents claim they are not getting
interference complaints," Sumner noted. "If we let them claim their
systems are 'clean' when we know they aren't, shame on us."

Interested individuals and organizations may file comments via the
Internet, using the FCC's Electronic Comment Filing System (ECFS)
<http://www.fcc.gov/cgb/ecfs/>. In an unusual move, the FCC has added
another docket number to the BPL proceeding. That could complicate filing
comments and may lead to some confusion. Although the original FCC BPL
Notice of Inquiry last April bore ET Docket 03-104, the recent BPL NPRM
carries an additional docket number--ET Docket 04-37. The ARRL advises
those posting comments to use the main ECFS page and file their comments
on both proceedings--ET Docket 03-104 and ET Docket 04-37.

When submitting a comment or viewing filed comments, ECFS users should
type "03-104" or "04-37" (without quotation marks but including the
hyphen) in the "Proceeding" field of the ECFS on-line form. Do not use the
NPRM's FCC document number when filing or searching for comments. The ECFS
permits attaching a file containing detailed comments prepared off-line.

ARRL President Jim Haynie, W5JBP, will discuss the various implications of
BPL with overnight radio talk show host Art Bell, W6OBB, on the Saturday,
March 20, edition of the syndicated interview and call-in program Coast to
Coast AM <http://www.coasttocoastam.com/>. Their interview is scheduled to
air during the show's first hour (Sunday, March 21, 0600 UTC). The
toll-free call-in number for Western US listeners is 800-618-8255. For
Eastern US listeners it's 800-825-5033. First-time callers may use
775-727-1222. The "Wild Card Line"--for any caller--is 775-727-1295. The
popular program, distributed by Premiere Radio Networks, airs live nightly
from 10 PM until 2 AM Pacific Time on 430 stations and is available in
every state. It's also available via the Web
<http://www.coasttocoastam.com/streamlink/about.html>.




~*-.,_,.-*~'^'~*-.,_,.-*~'^'~*-.,
Joe Buch
-*~'^'~*-.,_,.-*~'^'~*-.,_,.-*~'^


_______________________________________________
Swprograms mailing list
Swprograms@xxxxxxxxxxxxxxxx
http://dallas.hard-core-dx.com/mailman/listinfo/swprograms

To unsubscribe:  Send an E-mail to  swprograms-request@xxxxxxxxxxxxxxxx?subject=unsubscribe, or visit the URL shown above.