Subject: [NEXTEL-1] ARRL Seeks Clarification of FCC Response to BPL Interference Complaint.

From: [email-masked]
Date: Mon, 02 Aug 2004 09:24:38 -0400

ARRL Seeks Clarification of FCC Response to
BPL Interference Complaint

NEWINGTON, CT, Jul 23, 2004--The ARRL wants the FCC to further explain
its recent response to a North Carolina amateur's complaint of BPL
interference. FCC Office of Engineering and Technology (OET) Deputy
Chief Bruce A. Franca replied July 22 to an April 27 BPL interference
complaint from Thomas A. Brown, N4TAB, of Wake Forest. Brown had
complained of BPL interference to his amateur HF mobile station
emanating from a Progress Energy Corp (PEC) BPL field trial in the
Raleigh area.  In his letter, copied to ARRL, Franca said an on-site
investigation had concluded that PEC's BPL trial "is in compliance" with
FCC rules and that the company's ham band notching efforts "are
effective" to avoid the potential for harmful interference. ARRL CEO
David Sumner, K1ZZ, however, cited evidence to the contrary.

"It is not at all clear that the tests and
measurements taken by the FCC . . .
established the absence of harmful
interference to licensed stations," Sumner
responded July 22. He said the League
would like the OET to make its test report
available to the general public or at least to
the League for technical review and
comment. The ARRL also wants to know
what steps PEC took between April 27
and June 28--when the FCC began its
testing--to address interference
complaints from Brown and several
other radio amateurs.

The FCC defines as "harmful" any interference that "seriously degrades,
obstructs or repeatedly interrupts a radiocommunication service
operating in accordance with the Radio Regulations."

According to Franca, FCC personnel "undertook extensive testing and
measurements" of the PEC BPL system between June
28 and July 2. The complainant--Brown--says the FCC delegation never
contacted him while it was in North Carolina. Franca
says FCC measurements indicated notch depths averaging 24 dB below Part
15 emission limits, which he characterized as
"sufficient to eliminate any signals that would be deemed capable of
causing harmful interference, including interference to
amateur operations."

Franca maintained that "in no instances" were signal levels high enough
to "cause serious degradation, obstruction, or repeated
interruption" of amateur mobile or fixed communications. He conceded,
however, that notching on 10 meters was somewhat
less effective at the low end of the band and said the FCC would
instruct PEC and its partner, Amperion, to widen its notch
there.

Sumner noted that the Part 15 device operators "must eliminate all
harmful interference, and therefore in some cases must
achieve more--in certain cases, considerably more--than a 24 dB
reduction in order to be in compliance." He also cited recent
reports from amateurs in the area indicating that strong BPL
interference continues in parts of the PEC trial zone.
"From consulting with the amateurs who have been and continue to receive
harmful interference from the Progress Energy trials,
we find that while the interference has been reduced (but not
eliminated) in some parts of the amateur bands, it continues
unabated in others," Sumner told Franca. Amateurs in the Raleigh area on
July 17 and again July 22 monitored a BPL signal "at
full strength and causing harmful interference" from 14.290 to 14.350
MHz. "Harmful interference" also was reported in the first
100 kHz of 15 meters as well as on the WWV/WWVH frequencies of 15.000
and 20.000 MHz and on several international
broadcasting bands.

"Even in the notched bands," Sumner said, "the interference was still
evident on ordinary amateur equipment." He said it's clear to ARRL that
the system's Holland Church Road site--where the most recent amateur
measurements were taken--is in violation of Part 15.

For his part, Brown--an engineer with considerable RF experience--said
he was glad the FCC finally took some action but found some of Franca's
assertions "very troubling." He told ARRL that his 14-page complaint
cited interference "sufficient to mask a weak signal," although it did
not register on his S meter. "S0 is still microvolts of signal level,"
he pointed out. An active Amateur Radio Emergency Service District
Emergency Coordinator, Brown said it's not unusual to have to copy
similarly weak signals during an HF emergency net.

"This was an action on behalf of the FCC simply to show action," Brown
asserted. "I suspect the principal reason for their coming down here was
to say they've actually done something." He also worried that the FCC
was attempting to define a standard of "acceptable interference" within
the framework of what constitutes "harmful interference."
"If it interferes, it interferes," he maintained.

In his letter Sumner also requested that the FCC clarify some additional
aspects of its testing and measurement, including
specifics on tests at two fixed Amateur Radio station locations where
Franca said the FCC observed "no BPL interference" on
ham frequencies, and what kind of amateur equipment was used to "show
little field strength or observable signal levels in the
notched bands," as Franca reported.

"Until these points can be clarified," Sumner concluded, "we trust that
the Commission will not permit its conclusion to be
erroneously represented as having given the Progress Energy trials a
'clean bill of health.'
http://www.arrl.org/news/stories/2004/07/23/5/?nc=1

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