Subject: [NEXTEL-1] Comment Deadlines Set for Proposed BPL Rules

From: Marcelrf <[email-masked]>
Date: Sat, 20 Mar 2004 17:38:07 -0500

Comment Deadlines Set for Proposed BPL Rules

NEWINGTON, CT

March 18, 2004

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 NPRM text appeared March 17 in 
The Federal Register. 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. 

"It's important to remember four things," Sumner said. 
"First, this is not a proceeding to 'permit' or 'authorize' BPL. 
BPL is already permitted under the existing Part 15 rules." 

"Second, the NPRM reaffirms the important principle 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 nor can we assume that 
the principle will be honored in practice." 

"Third," Sumner continued, "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 we continue to believe firmly that BPL is a 
very bad idea, arguing that the FCC should 'ban BPL' will 
not get us anywhere." Instead, Sumner said, 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," 
he said. "There is far more evidence of that now than 
there was when the FCC opened its Notice of Inquiry 
last April." 

Sumner 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. 

Access BPL, a form of carrier current or power line carrier 
(PLC) communication, would apply RF in the HF to low-VHF 
range to existing low and medium-voltage exterior power 
lines to distribute Internet and broadband services. It was 
the aspect of feeding RF signals into outdoor power lines 
that initially raised Amateur Radio concerns regarding 
potential interference. 

Carrier current systems 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. 

At the FCC open meeting where the NPRM was adopted, 
Commission staff spoke of requiring that the BPL industry 
maintain a database accessible to the public to assist in 
locating BPL system operators. However, the actual 
proposals contained in the NPRM do not mandate a publicly 
accessible database. "These and other shortcomings must 
be resolved in order for interference mitigation to be an 
acceptable strategy in the case of fixed stations," Sumner said. 

The League also wants the FCC to establish performance 
standards for BPL interference mitigation. "To offer any real 
protection to licensed services, the rules must require that 
interference be resolved immediately," he said. "There must 
be severe enforcement penalties for failure to resolve a 
complaint in real time and for failure to maintain the database." 

Interference mitigation for mobile stations "is clearly is 
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. We are in 
the process of determining scientifically what that limit must 
be." 

The League especially encourages anyone, particularly 
radio amateurs, who has actually experienced BPL 
interference to file detailed comments documenting 
the interference. "It is extremely important that anyone 
who has suffered interference that is confirmed to have 
been caused by BPL to get their experiences into the 
record, in detail," Sumner said. "BPL proponents claim 
they are not getting interference complaints. If we let 
them claim their systems are 'clean' when we know 
they aren't, shame on us." 

Sumner said the League also will continue to encourage 
"affected interests outside the amateur community" to 
comment. The League urges anyone who opposes BPL t
o file comments, either supporting the ARRL's comments 
or by offering their own arguments. 

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. Another 500 
or so comments have shown up on ET 03-104 since the 
FCC issued its BPL NPRM, while some two dozen comments 
have been posted in response to ET Docket 04-37. 

The FCC's ECFS Express system still provides for filing brief 
comments on ET Docket 03-104, but 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. 

 http://www.arrl.org/news/stories/2004/03/18/100/?nc=1

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