Newington, CT, Oct 21, 2004

The ARRL again has asked the FCC to immediately shut down a broadband over
power line (BPL) field trial in the Cottonwood, Arizona, area that it says
is interfering with Amateur Radio communication. The League's second
shutdown request, sent October 11, accuses the FCC of doing "absolutely
nothing" to enforce its rules or to protect licensed services from
interference. In an accompanying 12-page technical analysis, the ARRL also
cast serious doubt on the accuracy--and possibly the integrity--of the BPL
system's FCC-required six-month report, filed more than two months late. Its
review of the report from system operator Electric Broadband LLC (EB), the
League said, indicated inconsistent test results demonstrating that ambient
noise conditions at the test sites "were clearly misstated".

"To be blunt, as can be easily determined from the EB report itself," ARRL
General Counsel Chris Imlay, W3KD, wrote in a cover letter to the ARRL's
technical analysis, "one of two things occurred: either (1) EB altered the
data to suit its false conclusion that the system is operating in accordance
with FCC rules; or (2) its technical consultants were not qualified to
conduct the tests and glaringly misinterpreted, among other things, the
source of noise generated internally in their own test equipment."

"The EB test results are completely compromised and cannot be utilized in
order to determine whether or not the system is operating in accordance with
FCC Part 15 rules," Imlay went on to say. "ARRL has previously established
that the system is operating substantially in violation of Part 15 rules and
is causing actual interference" on ham bands.

The ARRL said that EB's report further indicates that in the low-VHF Public
Safety allocation at 30-50 MHz, "the BPL system is operating at radiated
emission levels significantly in excess" of those permitted under Part 15
rules.
In its report EB claimed to have spent "significant time and effort" looking
into interference complains from hams, running tests and "taking steps to
mitigate any possible interference" the system was causing. It even invited
the FCC to come and see for itself.

EB and utility APS have been operating the BPL experiment at two Yavapai
County, Arizona, sites since June under a Special Temporary Authorization
(STA) the FCC granted EB in March. EB's six-month report included input from
APS, Mountain Telecommunications (MTI), which handles system operations, and
Mitsubishi Electric Power Products Inc (MEPPI), the BPL equipment designer
and manufacturer. The League pointed out that the STA now has expired "but
the system apparently continues to operate nevertheless."

A graph from the EB six-month report purporting to show measured levels with
the BPL system on (green) and off (red) between 13 and 23.3 MHz. ARRL
contends that if the data are accurate, "turning the BPL system on [would
have] the impossible effect of dropping the noise level in the spectrum it
uses by 30 dB." If the BPL data were increased by 30 dB to match ambient
noise levels, the BPL signal would exceed the FCC Part 15 emission limits,
the League analysis concluded.

In its technical analysis, the ARRL said EB continues to deny any
interference issues associated with its system, despite continuing
complaints and "detailed and accurate" technical showings submitted by
Cottonwood-area amateur licensees. Testing done in early September shows
clearly "that BPL signals were present at various sites on frequencies where
APS and EB claim it was not," the ARRL analysis asserted. The League also
charges that EB's test methodology was flawed and not up to industry or
regulatory standards.

The League conducted its own testing of the Cottonwood system this past
summer. That testing indicated levels of radiated RF energy on amateur HF
allocations were "extremely high" and well in excess of the FCC Part 15
levels with which EB told the FCC it would comply.

The FCC prompted release of EB's six-month report in a September 1 letter
that took note of "several complaints" alleging interference to Amateur
Radio operations from the experimental system. It also mentioned ARRL's
August request, filed on behalf of Cottonwood-area amateurs, that the FCC
shut down the system, revoke its STA and fine the system's operators. The
first Amateur Radio complaint, filed in June, cited testing by the Verde
Valley Amateur Radio Association (VVARA) in the 1.8-30 MHz range. It
asserted that BPL interference makes attempts at ham radio communication
useless. VVARA submitted a lengthy and comprehensive report to the two
companies and to the Commission in late July detailing interference issues
arising from the Cottonwood BPL field trial.

In late September, the VVARA BPL Interference Committee met with MTI and APS
representatives, who indicated that the BPL system operators had decided to
proceed with "notching" amateur HF frequencies. A representative from
Electric Broadband was not present at the meeting, VVARA says.

http://www.arrl.org/news/stories/2004/10/21/1/?nc=1