Technical Topics, December 2003
Anti-BPL Forces Muster For Battle
On November 7, 2003 the American Radio Relay League (ARRL) sponsored a meeting of various organizations that had previously expressed at least a cautionary posture to BPL regarding the FCC’s Notice Of Inquiry 03-104. The National Association of Broadcasters in Washington, DC hosted the meeting. I represented NASWA and the interests of the entire shortwave listener community. The ARRL has published their summary of the meeting in the ARRL Letter, Vol. 22, No. 45, November 14, 2003. Quoted statements in this article are from that letter. You can access that letter via the ARRL web site at: http://www.arrl.org/arrlletter/.
Here are some observations from my personal notes.
One would think, that with the future of shortwave broadcasting in North America at stake, companies whose sales depend in large measure on shortwave radio would have been well represented. Only Yaesu, of all the receiver manufacturers and retailers, was present and ably represented by Chip Margelli. He is with the Engineering/R&D Department of Vertex Standard’s Amateur Division and traveled from California to make important contributions to the discussion. However, Icom, MFJ, Sangean, Kenwood, Eton Corp. (Grundig North America), Grove Enterprises, and Passport To World Band Radio were invited to attend but for one reason or another did not show.
Many amateur radio organizations were represented at the meeting. The ARRL was there in spades including Dave Sumner, CEO; Paul Rinaldo, Manager of Technical Relations; Chris Imlay, General Counsel; and several representatives of the League’s Washington lobbyist firm. In addition several representatives of the Amateur Satellite Corporation (AMSAT) and the Amateur Radio Research and Development Corporation (AMRAD) attended.
A number of “inside the government” agencies participated as observers. They included the Department of Defense (DoD), ARINC, and The National Science Foundation (NSF). We all know what the DoD does. ARINC is a company that plans, installs and operates among other things the HF radio network used by the FAA for communications with aircraft. The NSF supports and funds radio astronomy telescopes. Some worldwide radio astronomy allocations are threatened by deployment of BPL technology.
Other represented organizations that do not fit into any of the above categories included NASWA, the National Association of Broadcasters, the Consumer Electronics Association, and APCO International, the organization of public safety entities. George Jacobs represented The National Association of Shortwave Broadcasters (NASB). He heads George Jacobs & Associates, the engineering consulting firm representing many NASB member broadcasters to the FCC. He also has a long and distinguished background with the VOA and brought a reasoned and mature Washington-insider perspective to the BPL issue.
The primary purpose of the meeting was to share current information on where the NOI process stands and to allow each represented organization to express their specific concerns.
As you may remember from previous Technical Topics columns, one solution the BPL proponents have put forth is to provide protection to amateur radio by notching out certain frequencies. I expressed the hope that all the attendees would reject that concept. Sparing amateur radio bands, for example, of interference will only mean that the energy will be diverted to frequencies used by other services like shortwave broadcast. I expressed the desire that we all work together to squash BPL rather than support a “not-in-my-back-yard” approach. I urged the attendees to avoid this trap and instead present a united front against BPL that protects all licensed spectrum users.
I also tossed out a possible argument that might be made that shortwave broadcasting and the right to freely access information should be protected under the First Amendment of the US Constitution. Those present with experience interfacing with the current FCC commissioners did not think such an argument would fall on friendly ears at the FCC. Another attendee pointed out that an argument could be made that BPL would actually expand most people’s ability to access news and information by enhancing the ability to get high-speed Internet access. Instead of restricting free speech or a free press, it could be argued that BPL would actually expand these protected rights. Knowing a brick wall when I hit it, I quickly abandoned the idea.
The ARRL reported on the current status of their tests and field trials. A video presentation showed the interference on a typical amateur radio receiver at two different test locations. One site used a form of digital spread spectrum technology. The interference sounded like what some have described as a very noisy Geiger counter. Rapid clicks were heard presumably in sync with packet data transfers. The other site used frequency division multiplexing. In this technique approximately 1000 separate carriers, each with FSK modulation, could be heard across the HF spectrum. As the receiver was tuned across the band, one heterodyne after another could easily be heard. The video showed the S-meter running S-9 on each carrier. The antenna for this test was a short horizontal dipole mounted a few feet above the roof of a station wagon as it drove down the road under the power line. Signals could be detected up to one kilometer from the power line. If you have a high-speed Internet connection, you can download the video from the ARRL web site at:
http://www.arrl.org/tis/info/HTML/plc/#Video.
In the November edition of the NASWA Journal I related the contents of a speech by FCC Commissioner Abernathy in which she projected unabashed support for BPL ignoring the thousands of comments warning of the interference potential of BPL. The ARRL CEO, Dave Sumner, related the gist of a communication he had with Commissioner Abernathy’s Senior Legal Adviser, Matthew A. Brill. Brill is reported to have said, “We regret that the Commissioner’s remarks may have been interpreted as suggesting an absence of concern over harmful interference.” Mr. Brill is further quoted as saying Commissioner Abernathy did not intend to suggest that BPL “necessarily will emerge as a viable platform or that it does not present interference issues.” Brill assured the ARRL that, “ensuring that BPL and all new technologies avoid causing harmful interference to licensed RF users is a bedrock position for Commissioner Abernathy.” Attendees at the meeting interpreted that response as good news.
The city of Manassas, Virginia has decided to provide BPL connectivity for all its citizens and businesses over its municipal power system. ARRL has put the City of Manassas “…on notice that on behalf of its members who live in and use public thoroughfares of Manassas, the ARRL will ensure that there is full compliance with the FCC regulations.”
AMRAD has purchased some HomePlug modems to test their susceptibility to amateur radio radiation. In one test the antenna was located about 15 meters from the modems. At a transmitted power of only 10 watts on 14 MHz, 80% of the packets were interrupted. At 100 watts all communications ceased. At higher power, RF irreversibly damaged the modems. With amateur radio operators presently permitted to use output powers up to 1500 watts, it is feared that once BPL is widely deployed and enough modems damaged, the FCC will be under the gun from the BPL lobby to severely reduce authorized power levels for amateur radio.
The US Government representatives were limited in how much they could reveal about what was happening inside their agencies. They stated that they were there to learn as observers. They did leave me with a strong impression that the National Telecommunications and Information Administration (NTIA) of the US Department of Commerce is moving ahead with their own independent assessment of the interference potential of BPL technology. The NTIA is responsible for coordinating radio communications issues of the various elements of the US Government much as the FCC regulates private radio communications in the USA. The presentation by Paul Rinaldo of ARRL actually contained a photo of an NTIA truck parked in Emmaus, PA, the site of one of the BPL tests currently in progress.
The representative from ARINC told a horror story of an aeronautical HF receiving site near Half Moon Bay, California. In the adjacent community, off-the-shelf, in-home, power-line modems are widely in use. (Californians tend to be early adopters of new technology.) Some frequencies previously used at this site are no longer useful because of interference from the nearby modems. Even worse, there are so many different sources of interference that normal direction finding techniques cannot be used to locate specific homes with such devices.
Representatives of public safety organizations were opposed to any solution that involved use of the low VHF band frequencies. They pointed out that many volunteer fire departments still use those frequencies and cannot afford to relocate to an 800 MHz trunked technology. They also pointed out that the federal government and many state police organizations use HF frequencies for long haul emergency communications.
Near the end of the discussion, George Jacobs opined that it seemed to him that the best arguments against BPL would be based upon the need for HF/VHF communications to support homeland security and safety of life. Another attendee said that hitching our arguments to homeland security could be dangerous because BPL proponents could argue that high-speed Internet access via BPL could actually enhance the ability of many to communicate via the Internet.
Dave Sumner presented some ideas for future possible actions by opponents of BPL. Presentations to FCC engineers and commissioners were mentioned. Other target government agencies were also suggested like NTIA and even the Department of State. One problem that was noted by ARRL is that the amateur radio community was overwhelmingly represented in the 5000 or more comments received by the FCC to date. A more diverse population of opponents would enhance the chances of leaving a lasting impression at any presentation. I volunteered to represent NASWA and shortwave listeners in any presentations the ARRL may schedule in the future to the FCC or other agencies.
The BPL issue is presently not on the RADAR screen of the US Congress. ARRL reported that BPL industry representatives have been talking to staff members of telecommunications subcommittees but that is as far as the process has gone to date.
A Notice of Proposed Rule making (NPRM) is expected some time in the first quarter of 2004 if the FCC decides to proceed. Once that notice is promulgated there will be another round of comments and reply comments. Stay tuned.