RadioBanter - response to UPLC new release/comments on BPL

Follows, for anyone who's interested, my response to the insulting, inaccurate press release (and comments to the FCC) from the UPLC:

Dear Ms. Paterson,

I find the content of your press release (which I understand is derived from comments that UPLC has filed with the FCC) to be inaccurate, misleading, and gratuitously insulting to amateur radio operators and the Amateur Radio Service in general.

In fact, the inaccuracies are so glaring that I am tempted to request that the FCC apply its rules requiring truthfulness in statements made to the Commission and consider sanctions against the UPLC.

I will comment, in context, in the copy of your press release below. Hopefully your e-mail program will preserve the distinguishing color I've used for my comments in composing this message to make it easy for you to identify my comments. Please note that these comments are my *personal* views, as an individual amateur radio operator and an RF engineer of over 33 years experience, and that I am not speaking in any official capacity (for my employer or any of the organizations that I sometimes represent in regulatory matters).

FOR IMMEDIATE RELEASE
June 22, 2004

For More Information, Contact
Mary Alice Patterson
Media Relations Assistant
1.202.833.6811

UPLC Sets the Record Straight on BPL Interference

WASHINGTON - The FCC's proposals are appropriate;

They are not ... the current radiated emissions limits for carrier current systems were developed long ago in contemplation of some finite number and distribution of essentially point-source radiators, NOT in contemplation of "access BPL," which employs what amounts to a huge, geographically distributed antenna system that field measurements show radiates at (and in some cases above) those limits virtually everywhere it exists.

NTIA's recommendations and ARRL's naysaying are misguided.

As an RF engineer, I find NTIA's conclusions that "access BPL" does pose a significant risk of interference to licensed HF/low VHF communications services that use the spectrum "access BPL" proposes to use to be consistent with my own field measurements with calibrated test equipment, the ARRL's measurements (and those of their independent contractor), and the growing body of evidence from the various "trial areas" around the country, where interference has been documented, but not resolved by the responsible BPL system operators.

The United Power Line Council (UPLC) forcefully replied to concerns about harmful interference from BPL in reply comments filed today, and urged the FCC to move forward quickly to develop rules that will encourage more development and deployment of BPL services to the public. Specifically, UPLC expressed its concerns with findings and recommendations by the National Telecommunications and Information Administration (NTIA) that overstate the risk of interference from BPL.

In my view, if anything, NTIA's position UNDERSTATES the risk of interference from BPL. The "commerce" side of NTIA is clearly being driven by political forces to "soft-pedal" the risk to some degree.

NTIA's proposals would place undue operating restrictions and impose arbitrary measurement guidelines that threaten to delay the deployment of BPL or preclude it altogether;

NTIA's proposals don't go far enough ... power companies have been notoriously slow to resolve simple, localized radio interference resulting from such simple things as bad insulators, etc. I have little/no confidence that they will be more responsive in dealing with interference from BPL - and the results to date from the "trial areas" support the conclusion that the level, and promptness, of resolution of interference complaints is more or less non-existent, despite the requirements of the FCC's Part 15 rules that BPL operators cease operation unless or until they can resolve interference.

The BPL industry's response to interference concerns/complaints to date has been largely a game of denial and stalling.

however, the UPLC expressed its interest in working with NTIA going forward. Moreover, UPLC did agree with NTIA that BPL "has been studied to death already and the FCC should adopt rules without further delay."

This is absurd. Despite the BPL industry's denials, and the fact that significant interference has been documented in limited "trial areas" - interference that will only affect wider areas and be exacerbated by large-scale deployments with large numbers of users - there are many unanswered questions about if/how BPL can adequately protect the licensed users of the HF/low VHF spectrum.

Unless/until these questions are resolved, "access BPL" deployments should be put on hold.

UPLC reminded the Commission that BPL is not just another broadband access platform, but one that enables applications in ways that other technologies do not by providing enhanced utility applications, home networking, symmetric speeds, and low latency for a variety of services. Unique applications will improve the efficiency and reliability of electric service to utility customers as well as promote broadband competition for consumers, carriers and ISPs - saving lives, reducing electric generation costs, remedying the digital divide and conquering the DSL- cable duopoly.

This is clearly little more than self-serving marketing rhetoric.

HF/VHF "access BPL" will be limited in the data rates that it will be able to support, due to the hostile nature of the transmission medium (MV and HV power distribution lines) that are not good carriers of RF, have high noise levels, impedance discontinuities, etc.

As for the BPL industry's attempts to "push the hot button" of "universal broadband" (alluding to serving rural America), the economics aren't there for a system that requires repeaters on the order of every 300-500 meters along the lines to overcome noise and losses. I don't see how anyone can make a business case for serving rural customers (many repeater spans apart) in an economically viable fashion, given the large amount of infrastructure that would be required to reach them.

(It is interesting to note that all of the BPL "trial areas" that I am aware of are in urban or suburban areas - not rural areas. In many cases, these areas already have either cable modem service, or DSL service, or both ...)

UPLC also commented on amateur radio opposition to the technology, urging the Commission to ignore "armchair amateurs that still use vacuum tube transmitters"

This gratuitous attack on amateur radio operators is inaccurate, offensive, and uncalled for.

The Amateur Radio Service, including ARES and RACES, provide essential emergency and disaster communications services to government EMS agencies and private agencies such as the Red Cross and the Salvation Army.

Amateur Radio has been recognized by Congress, the Department of Homeland Security, and a plethora of state, local, and private emergency response/disaster relief agencies as a vital part of America's national emergency communications infrastructure.

and listen to the reputable companies and entrepreneurs who are the real experts on BPL and who have overcome enormous technical obstacles to make BPL a reality in the U.S.

Are you referring to the "experts" who deny the existence of any interference issues, despite a large (and growing) body of evidence to the contrary?

Are you referring to the "experts" who insist that "power lines don't radiate as antennas" and/or "BPL is a point source radiator," despite the fact that these statements are contrary to both well-established electromagnetic theory and field measurements?

All the field trials over the years in various parts of the country have shown that the risk of interference from BPL is extraordinarily low, because it produces only minimal radio frequency energy at a few points in the system.

This is patently false, as evidenced by interference complaints, and all of the measurements and studies referenced above.

Moreover, these systems will incorporate adaptive interference mitigation capabilities that will effectively remedy any interference that might result to fixed and mobile operations in the High Frequency (HF) band (1.7-80 MHz).

Where's the beef?

These unspecified, unimplemented "mitigation capabilities" are, for the foreseeable future, an unfulfilled promise (and a promise that may never be fulfilled).

Besides, in your own words above, you imply that imposing such requirements is something that you oppose.

Finally, as pointed out above, electric utilities have generally been dismally poor at resolving even simple, incidental power line interference problems - and those operating BPL "trial systems" have, to date generally denied interference and done little or nothing to resolve it. (A notable exception is the case of Alliant Energy of Cedar Rapids, IA - who have recently terminated their BPL trials as a result of their inability to remedy interference that has existed since their system went active on March 30, 2004 - see http://www.arrl.org/news/stories/2004/06/28/2/?nc=1) - but only after the ARRL filed a formal complaint with the FCC asking that they order the system shut down and impose a $10,000 fine.)

"BPL is an exciting technology with a promising future, but it's dependent on the FCC to develop rules that will encourage companies to deploy systems, both for better electrical service and competitive broadband," stated Bill Moroney, President and CEO of UPLC.

The FCC's primary responsibility, under its own rules and the ITU Radio Regulations, is to protect the many and varied licensed services that have allocations in the 2-80 MHz frequency range from the harmful interference that (at least the current incarnations of) "access BPL" cause.

"If the goal of this Administration is universal affordable broadband access by 2007, BPL is the best hope of achieving it."

With all due respect - hogwash - there are other, readily available, non-interfering solutions such as wireless broadband access in higher, more suitable frequency ranges. As stated above, my personal view is that the "promise" of BPL to "serve rural America" is a pipe dream because the huge amount of infrastructure that would be required would render it economically infeasible at any reasonable cost to rural consumers and businesses.

[I snipped the "who we are" paragraphs at the end of your press release, since I presume that you know who you are ...]

Carl R. Stevenson - wk3c
Grid Square FN20fm
http://home.ptd.net/~wk3c
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NCI-1052
Executive Director, No Code International
Fellow, The Radio Club of America
Senior Member, IEEE
Member, IEEE Standards Association
Member, IEEE-USA CCIP
Chair, IEEE 802.18 Radio Regulatory Technical Advisory Group
IEEE Liaison to ITU-R
Chair, Wi-Fi Alliance Regulatory Committee
Co-Chair, Wi-Fi Alliance Legislative Committee
Life Member, ARRL
Member, QCWA (31424)
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