[Swprograms] Tracy Wood on BPL NPRM

[Joe Buch <joseph.buch@xxxxxxx>]

You may know Tracy Wood from his long association with the Winter SW Fest.  He filed comments with the FCC on the BPL NPRM.  I thought you all might benefit from his eloquent assessment of the problem from the perspective of an SWL.


Before the
Federal Communications Commission
Washington, D.C. 20554

In the Matter of )
Amendment of Part 15 )
regarding new requirements )
and measurement guidelines )
for Access Broadband over ) ET Docket No. 04-37
Power Line Systems )

COMMENTS OF NOTICE OF PROPOSED RULE MAKING (NPRM)

To the Commission:

Below are my comments regarding the current FCC
proposal to permit sharing of critical spectrum by
Broadband Over Powerline (BPL) services.
Most BPL implementations will likely use a large
portion of the High Frequency (HF) radio spectrum. The HF
spectrum is a unique, irreplaceable resource. No other
medium offers communications hundreds or even thousands of
miles without the use of terrestrial- or satellite-based
repeaters.

As a regular listener of international shortwave radio
I receive news, political views, religious opinions, and
entertainment programs from diverse nations around the
world. The foreign nations broadcasting to the US have an
expectation that the American government (or its
infrastructure) will permit the direct flow of information
into Americans' homes. BPL interference represents a threat
to this free flow of information.

The Commission must recognize that shortwave broadcast
radio remains a viable means for the public to follow world
events. It is a highly portable, low-cost alternative that
does not require an Internet connection (ISP), monthly
charges, or expensive computers and software. In fact, most
public libraries do not permit listening to comparable
streaming media sources on their free access terminals, thus
limiting the Internet as a truly free, replacement audio
alternative.

Many BPL field trials have attempted to relieve amateur
radio users of direct interference in their spectrum, (i.e.
filter placement between 14.0-14.4MHz). Unfortunately no
such similar relief has been offered to the shortwave
listener community and our WRC-allocated frequencies, e.g.
49 meters (5.9-6.2Mhz). If BPL interference is permitted in
the international broadcast bands, my ability will be
threatened to hear ITU-allocated broadcasters such as Radio
Nederlands (6.02Mhz) and Radio Canada International
(9.755MHz). The US government is a signatory to ITU/WRC
treaties and its expectation of jamming-free and/or
interference-free listening.

If BPL is to be deployed, data providers must provide
equal "quite zone protection" to the international broadcast
frequencies (listed in Part 73, FR. Sec 73.702) as they do
to amateur radio frequencies.

Military, government, and civilian aid agencies still
use HF as critical backup during natural disasters and
crisis situations. Implementing a relaxed BPL environment
indeed will threaten our disaster recovery capabilities.
Gateway radio sites could suffer from heightened levels of
Part 15 HF interference, degrading their ability to receive
voice and data transmissions.

Today's powerlines are designed for carrying power, not
transmitting wideband data. There are already plenty of
other technologies that could be employed to provide rural
and urban consumers with equal-or-better broadband service
without endangering this critical HF spectrum
resource. Among these technologies are MMDS, satellite,
data-channel-over HDTV, remote-fiber-MUX DSL, broadband
cable.

Today's consumers are overwhelmed with new
technological services. In the past the Commission has
permitted "corrective measures" to make these services more
user friendly. Signals to auto-set VCR/TV clocks, V-Chips,
telephony number transparency, RDS are just a few features
that aid the consumer.

Industry and the Commission have yet to offer a
consumer-friendly method the identify and mitigate potential
BPL interference. If power transmission companies
potentially generate interference, there must be a simple,
standardized technique for the consumer to differentiate BPL
interference from other common sources: DSL harmonics,
arc'ing power transformers, motors, automobile ignition
noise, etc. Cable TV providers have long used "RF beacons"
to identify and mitigate potential interference to aircraft
and public safety frequencies.

Consumers must have tools at their disposition to
similarly track BPL interference sources. BPL cries out for
"decodable" marker frequencies on at least five published
frequencies across the spectrum (for example 4.3, 8.1, 10.5,
17.1, 23.8 Megahertz - at the Commissions' discretion). The
Commission must mandate all BPL providers implement
consumer-readable standardized telemetry streams on marker
frequencies. These telemetry streams would aussuage many
current spectrum users when battling Part 15 BPL
interference sources. If BPL is to go beyond the field
trial stage, these data providers must also augment the
reporting capabilities of their interference hotlines,
similar to the "call-before-you-dig" service desks. It will
be critical to insure multilingual staffing on these
"hotlines" as many shortwave broadcasters "target" their
diaspora in the US.

Finally BPL proponents must disclose the full impact of
their technology. BPL must be evaluated with government
agencies in charge of protecting our regional and local
power distribution infrastructures. As "Homeland Defense"
has become a major issue, a "Day Zero" evaluation should be
mandated with each new BPL rollout. Has there been full
disclosure regarding any potential risks to the powergrid
when modified for BPL with its HF and VHF signals? The
Commission must allow a residential "opt-out" policy that
blocks BPL signals from passing beyond the pole-mounted
"customer-entry" transformer.

I believe BPL can eventually be a positive technological
force, but only if there is a level playing field. This
equal playing field includes aggressive protection for
licensed users and shortwave broadcast listeners, consumerfriendly
interference identification, and powergrid-under-
BPL resilency testing.

Our spectrum is too unique of a resource to be lost to a
partially-developed technology.

Respectfully Submitted,
/s/
(Mr.) Tracy K. Wood
4561 Strutfield Lane #3416
Alexandria, VA 22311-4982
3 May 2004



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