Subject: [NEXTEL-1] It Seems to Us . . .Regulators or Cheerleaders?

From: [email-masked]
Date: Wed, 04 Jun 2003 01:02:19 -0400

It Seems to Us . . .Regulators or Cheerleaders?

By David Sumner, K1ZZ
ARRL Chief Executive Officer
June 1, 2003

Editor's note: Typically, only ARRL members get to read the "It Seems to Us
..." editorials that run each month in QST. We're posting this editorial
that appears in the June 2003 issue of QST in the hope that both ARRL
members and nonmembers might appreciate it and find it informative.

No one should doubt that the Federal Communications Commission (FCC) has a
difficult job. Its roots lie in the establishment of the Federal Radio
Commission (FRC) in 1927. The force behind the creation of the FRC was
chaotic interference that threatened to destroy the fledgling broadcasting
industry by driving listeners away. Too many stations were being put on the
air with inadequate coordination. In other words, the marketplace alone was
inadequate to control individual broadcasters' behavior; regulations were
needed to protect the industry from itself.

One of the FCC's obligations under the Communications Act is to "generally
encourage the larger and more effective use of radio in the public
interest." Like any resource, the radio spectrum is finite. One way to
ensure that the largest and most effective use of the spectrum can be made
is to prohibit unnecessary emissions. Thus, minimizing interference remains
a fundamental regulatory mission of the FCC.

On the other hand, U.S. policy is to encourage the provision of new
technologies and services to the public. FCC Chairman Michael Powell's
interpretation of this policy is that his Commission should be a
"cheerleader" for new technologies. On April 23 during an Open Meeting he
used that very word to describe the FCC's role with regard to the deployment
of a technology that gives us grave concern: broadband power line
communications, generally referred to as PLC but now dubbed BPL, for
Broadband over Power Line, by the FCC.

The reason for our concern is simple. "Access BPL" involves the introduction
of RF energy in the range from 2 to 80 MHz onto so-called "medium voltage"
power lines that run along nearly every road and street and into every
neighborhood. They are the lines that connect the transformer feeding your
home to the nearest substation. According to industry sources, data rates of
up to 20 MB/s are possible for distances of up to 2,000 feet, and of up to 3
MB/s for distances of up to 4,000 feet. Because the power lines are already
in place in existing rights-of-way, this makes the technology potentially
attractive for delivering broadband services such as Internet access.
"In-House BPL" involves much the same thing for LANs using the existing AC
wiring in the walls of homes and offices.

BPL does not require that this RF energy be radiated. However, as most of
you reading this page no doubt already have realized to your horror, it will
radiate for the simple reason that there's nothing to stop it. Power lines
are unshielded. They are designed to be transmission lines at 60 Hz, not at
HF or VHF. For a radio service such as ours that relies for its very
existence on the ability to detect and decipher weak signals, including from
our automobiles as we drive under these very power lines, BPL could be an
intolerable polluter of the radio spectrum. That this would be merely an
unintended consequence of BPL deployment -- collateral damage, if you
will -- does not ameliorate the situation.

What the FCC did at its April 23 meeting was to adopt a Notice of Inquiry
(NOI) regarding "Carrier Current Systems, including Broadband over Power
Line Systems" (ET Docket No. 03-104). In the words of the NOI:

Through this inquiry, we seek information and technical data so that we may
evaluate the current state of BPL technology and determine whether changes
to Part 15 of the Commission's rules are necessary to facilitate the
deployment of this technology. While BPL may be deployed under our existing
Part15 rules, the rules do not specifically provide measurement procedures
that apply to systems using the power line as a transmission medium. We
therefore seek comment on what changes, if any, we should make to our Part
15 rules to promote and encourage the new BPL technology and to our
measurement procedures for all types of carrier current systems. We further
encourage present deployment of BPL that complies with our existing rules,
noting that if, or when, our rules are modified, those rules will address
prospective compliance.

The Commissioners were rather effusive in their praise of BPL technology as
an additional competitor, along with cable and DSL, in the delivery of
broadband services to the public. Their favorable impressions were based
largely on a single carefully orchestrated "dog and pony show" to which they
had been invited in suburban Maryland. (Needless to say, we weren't invited.
We'd have brought along an HF receiver for them to listen to.) The NOI does
at least raise interference as an issue [emphasis added]:

In both Access and In-House high-speed BPL technologies, multiple carriers
spread signals over a broad range of frequencies that are used by other
services that must be protected from interference. In the spectrum below 30
MHz, incumbent authorized operations include fixed, land mobile,
aeronautical mobile, maritime mobile, radiolocation, broadcast radio,
amateur radio terrestrial and satellite, and radioastronomy. In the spectrum
from 30 to 300 MHz, incumbent authorized operations include fixed land
mobile, aeronautical mobile, maritime mobile and mobile satellite,
radioastronomy, amateur radio terrestrial and satellite, broadcast TV and
radio. This spectrum is also used for public safety and law enforcement, and
Federal government aeronautical radionavigation, radionavigation satellite
and radiolocation. Each of these authorized services in the spectrum must be
protected from harmful interference.

Rest assured that the ARRL will do everything in its power to hold the FCC
to that promise.

The deadline for comments was not set at press time but probably will be in
the latter half of June. We will be posting as much information as possible,
as quickly as possible, on the ARRL Web site http://www.arrl.org/ for use by
members and others interested in filing their own comments.

We have a long, hard fight ahead of us.

http://www.arrl.org/news/features/2003/06/01/1/?nc=1

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