Subject: [NEXTEL-1] A COMMUNICATIONS INTERFERENCE THREAT: BROADBAND OVER POWER LINES

From: [email-masked]
Date: Sat, 16 Aug 2003 23:15:13 -0400

A COMMUNICATIONS INTERFERENCE THREAT: BROADBAND OVER POWER LINES
July 22, 2003

Statement of the Problem

The Federal Communications Commission (FCC) is currently considering acceptance of
a new method of networking computers on a nationwide basis using existing commercial power lines to carry the signals. This method, known as Broadband over Power Lines, or "BPL", will disrupt and interfere with existing communications services, such as shortwave broadcast, aeronautical mobile, maritime mobile, government time and frequency standard transmissions, government research activities and amateur radio communications in the HF and VHF portions of the radio spectrum.
BPL Background

The FCC issued a Notice of Inquiry (NOI) in ET Docket 03-104 1 asking how the FCC should regulate the delivery of broadband telecommunication services to homes and businesses using electrical wiring to conduct high-speed digital signals. This technique is referred to as Broadband over Power Lines or "BPL". So-called "access BPL" would use existing overhead medium-voltage power lines to distribute Internet and broadband services to homes and businesses by coupling RF energy onto the power line.  Another form of BPL, "in-house BPL," uses electrical wiring inside a building to distribute digital signals. FCC Part 15 rules permit BPL, but its interference potential remains untested and unrealized, since no access BPL systems are in operation at this time. The American Radio Relay League (ARRL), an amateur radio organization, has filed a response that includes studies showing high levels of interference to other communications services in the HF and VHF spectrum should this system be implemented nationwide.
In announcing its BPL initiative earlier this year, members of the FCC could barely contain their enthusiasm for the technology, as indicated by their comments attached to the NOI. It is this general acceptance and eagerness to implement an untested system by the commissioners that concerns most users of the HF radio spectrum.
If the system suggested by the FCC in its NOI is implemented and commercial manufacturers are allowed to market these broadband devices in place of or in addition to the current computer network connection equipments, Here is what will happen:

1. Large numbers of users (hundreds of thousands or millions in a metropolitan area) will simultaneously be using these unregulated broadband radiation sources.

2. Multiple broadband signals radiated from the power lines will add together, making the many small signals into a very large broadband radiated signal emanating from every metropolitan area in the country.

3. The proposed radio frequency bands occupied by these millions of broadband radiation sources are subject to ionospheric propagation and thus the transmissions will not be limited to just line of sight distances. This means that

computer users in New York will interfere with existing licensed HF radio services in Detroit, Dallas, Miami, London, etc. and vice versa.
What is wrong with the BPL:

1. One of the FCC's primary functions is to regulate radio frequency radiation sources and prevent interference among various users of the RF spectrum through its licensing authority. The FCC has a responsibility to make sure that licensed users of the RF spectrum resource, no matter how insignificant in number, are protected from unlawful intrusion by commercial or government entities that want unrestricted access to the resource.

2. There are currently other means of supporting broadband interconnection services, such as coaxial cable, that do not radiate signals at all, provided that they are properly installed and maintained. Digital Subscriber Line (DSL) service is also available in some localities using the existing telephone network.
Nationally,

we already have broadband cable connections to most homes and businesses. In
fact, some places offer a choice of cable services. Although there are rural areas
without cable service at this point in time, RF satellite and microwave links are available to fill in the gaps in these service areas. Obviously, satellite and microwave are not as cost effective on a single user basis as having a new $20 gadget that one is able to connect between a computer and the power line.
3. BPL requires modification of the power lines to make it work, so the system is not an immediate "plug and play" solution. Installation of signal couplers and repeaters along the power lines are needed to communicate around existing power transformers and to make up for RF losses encountered in the long power line runs. The transmission losses encountered in BPL are both copper losses in the wires, and radiation losses. Therefore, the proponents of BPL in admitting the need to install repeaters, confirm that the system will act as jamming devices to other communications services. Instead of modifying power lines for BPL, effort should be directed to coaxial cable installation for those areas currently without

broadband access. Installing RF transmitters on utility poles to boost broadband signals on the power utility's long wire antennas (the power grid) makes no sense from either a technical or a social economic viewpoint. It only makes sense from a corporate economic viewpoint.
Peter Hansen
395 Chester Ct.
South Lyon, MI 48178
[email-masked]

http://www.qsl.net/miqrpclub/bpl.pdf

1 http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-100A1.pdf
2 http://www.arrl.org/announce/regulatory/et03-104/ARRL_BPL_Comments.pdf

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