questions of the day

Broadband Over Power Line Broadband Over Power Line and Amateur Radioand Amateur Radio

Ed Bruette, N7NVPEd Bruette, N7NVPARRL WWA Section ManagerARRL WWA Section Manager

[email protected]@arrl.org360-698-0917360-698-0917

Questions of the dayQuestions of the day

Who has been promoting BPL?Who has been promoting BPL? Is it a realistic threat to Radio?Is it a realistic threat to Radio?

Show Broadband over Show Broadband over Powerline Primer video Powerline Primer video

herehere

In the US, Regulated by FCC Part In the US, Regulated by FCC Part 1515

BPL has been legal all along under FCC BPL has been legal all along under FCC rulesrules

On October 14, the FCC made significant On October 14, the FCC made significant changes to the rules governing BPLchanges to the rules governing BPL

Although they spun it as rules to Although they spun it as rules to “enable” BPL, it “enables” only in that it “enable” BPL, it “enables” only in that it attempts to address interference issuesattempts to address interference issues

In reality, the new rules put significant In reality, the new rules put significant new restrictions on BPLnew restrictions on BPL

What Was Kept?What Was Kept? Absolute-maximum limits defined in Part 15Absolute-maximum limits defined in Part 15 Carrier-current must meet limits for Carrier-current must meet limits for

intentional emittersintentional emitters Part 15 also is clear that unlicensed devices Part 15 also is clear that unlicensed devices

such as BPL must not cause any harmful such as BPL must not cause any harmful interference and they must accept any interference and they must accept any interference caused to theminterference caused to them

Manufacturer responsible for FCC Manufacturer responsible for FCC authorization and maximum limitsauthorization and maximum limits

Operator responsible for harmful Operator responsible for harmful interferenceinterference

Both components to the rules are necessary Both components to the rules are necessary for Part 15 to workfor Part 15 to work

What is New?What is New?

Interference Database – Zip code and contact Interference Database – Zip code and contact informationinformation

Mandate to have ability to control frequency, Mandate to have ability to control frequency, power level and shut offpower level and shut off

Certification instead of VerificationCertification instead of Verification List of forbidden frequenciesList of forbidden frequencies FCC said interference would be “very rare” but FCC said interference would be “very rare” but

carved out 13 blocks of government spectrum that carved out 13 blocks of government spectrum that BPL couldn’t useBPL couldn’t use

Operate under “transition” rulesOperate under “transition” rules Devil in details – will define what constitutes Devil in details – will define what constitutes

interference?interference?

Intentional Emitter Radiated Intentional Emitter Radiated Emissions Limits - HFEmissions Limits - HF

Sec 15.209Sec 15.209 1.705-30.0 MHz -- 30 1.705-30.0 MHz -- 30 V/m at 30 V/m at 30

metersmeters These limits should protect users These limits should protect users

of the spectrum against of the spectrum against interference, yes?interference, yes?

No!No! If the absolute emissions limits were set to offer

unconditional protection to all radio services, the permitted levels would be unworkably low

Amateur Radio Service, by design, uses sensitive equipment and weak signals

The “legal limit” will result in a strong signal to nearby amateur HF installations

On 3.5 MHz, a half-wave dipole placed in a 30 V/m field will receive a –86.4 dBW signal (338 V across 50 ohms)

To amateurs, this is S9+16 dB – clearly harmful interference to typical amateur communications!

Harmful interference at even greater distances than the compliance distance is likely

The absolute limits are not enough to prevent interference to nearby receivers

Harmful InterferenceHarmful Interference Defined as the repeated disruption of radio

communications or any disruption of certain emergency communications services

Merely hearing a signal is NOT harmful interference 30 V/m at 30 m works to a degree for discrete

frequency signals If from broadband device, however, will interfere

with entire band(s)! 30 V/m works to a degree for isolated point

sources If from PLC, level will occur for entire length of line

in areas where access PLC is deployed!

The Voice of BPLThe Voice of BPL

Harmful Interference – the BPL Harmful Interference – the BPL PerspectivePerspective

""It is Progress Energy’s position and interpretation of the FCC's rules with regard to 'harmful interference' that any interference that may still exist is not 'harmful' as that term is defined by the FCC's rules," Len Anthony, PEC's attorney for regulatory affairs, told James Burtle, chief of the FCC's Experimental License Branch. "This level of interference does not seriously degrade ham radio operation or transmissions or cause repeated interruptions."

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

Anthony noted that since PEC can modify its Amperion BPL system to totally eliminate interference to fixed stations, "the only impact of any kind upon ham operations is upon mobile operators." PEC concluded that since BPL interference to mobiles would by "very short lived," the company is not causing harmful interference and is in "full compliance" with FCC Part 15 rules.

BPL MisconceptionsBPL Misconceptions

BPL is a solution for rural AmericaBPL is a solution for rural America• Not cost effectiveNot cost effective• No back up powerNo back up power

VOIPVOIP• No 911No 911

Connectivity during disastersConnectivity during disasters

How do I know it is BPL?How do I know it is BPL? It is possible to misidentify BPLIt is possible to misidentify BPL Each BPL system has a unique soundEach BPL system has a unique sound Some are spread spectrum – broadband noiseSome are spread spectrum – broadband noise Some are OFDM, broadband noise or multiple Some are OFDM, broadband noise or multiple

carriercarrier Onset vs spectrum is generally over about 100 kHzOnset vs spectrum is generally over about 100 kHz If the noise has a strong 60- or 120-Hz component, If the noise has a strong 60- or 120-Hz component,

it is probably “regular” power-line noiseit is probably “regular” power-line noise If heard every 10-50 kHz, as a buzz or as birdies, it If heard every 10-50 kHz, as a buzz or as birdies, it

is probably a computer, TV set or switch-mode is probably a computer, TV set or switch-mode power supplypower supply

Spectrum Chart: This shows the Spectrum Chart: This shows the present use of spectrum:present use of spectrum:

Spectrum with BPL from 2-80 MHz:Spectrum with BPL from 2-80 MHz:

BPL Could Interfere With:BPL Could Interfere With:

Emergency Emergency management management

National GuardNational Guard US Coast GuardUS Coast Guard U.S. MilitaryU.S. Military Fire DepartmentsFire Departments Law EnforcementLaw Enforcement

CAPCAP FAA FAA FEMAFEMA NASANASA Voice of AmericaVoice of America TV stationsTV stations Amateur and CB Amateur and CB

radioradio

Power Lines as AntennasPower Lines as Antennas EZNEC 3.1 used to model 300 feet EZNEC 3.1 used to model 300 feet

of simple electrical wiring (uses of simple electrical wiring (uses NEC-4, written by Lawrence NEC-4, written by Lawrence Livermore National Laboratories)Livermore National Laboratories)

ARRL’s modeling showed “gain” of ARRL’s modeling showed “gain” of –16 dBi on 3.5 MHz to +10 dBi on –16 dBi on 3.5 MHz to +10 dBi on upper HFupper HF

This is about the gain of a mobile This is about the gain of a mobile whip on 75 meters and a 3-whip on 75 meters and a 3-element Yagi on HFelement Yagi on HF

AnalysisAnalysis ARRL’s filing contained an ARRL’s filing contained an

analysis of the degradation of analysis of the degradation of HF Communications by Part-HF Communications by Part-15-level signals15-level signals

Over 70 dB increase in peak Over 70 dB increase in peak local noise – on entire length of local noise – on entire length of line – in whole neighborhoods! line – in whole neighborhoods!

Overseas measured studies Overseas measured studies showed similar results to ARRL showed similar results to ARRL calculationscalculations

Other organizations that Other organizations that share ARRL’s concerns:share ARRL’s concerns:

Federal Emergency Management AgencyFederal Emergency Management Agency National short-wave listener associationsNational short-wave listener associations Short-wave broadcastersShort-wave broadcasters AeronauticalAeronautical NTIA has done field measurements in NTIA has done field measurements in

Potomac, MD and Emmaus, PAPotomac, MD and Emmaus, PA They released a report on their findingsThey released a report on their findings

Is Amateur Radio Doomed?Is Amateur Radio Doomed? No! In a speech last year, FCC Commissioner Abernathy

stated that she envisioned that most rules that were restricting BPL could be removed.

In a letter issued several months later, she clarified that protection against harmful interference was a “bedrock” position.

In October, 2004, the FCC came out with an announcement of new rules that removed NO restrictions, but proposed to add requirements that apply to no other unintentional emitter

The work being done by amateur radio IS having an effect, and we can continue to drive home the point to the FCC and to electric utilities that power lines are not the right place to put high-speed digital signals

VideoVideo

Interference to BPLInterference to BPL Our test conditions:Our test conditions: Mobile Icom 706, with Mobile Icom 706, with

Outbacker Perth, curb side approximately 70ft Outbacker Perth, curb side approximately 70ft from house, 100+ feet from the BPL pole from house, 100+ feet from the BPL pole interface. interface.

BPL conditions: BPL conditions: Output level was normal. Output level was normal. System activity was low, however we had some System activity was low, however we had some control since we had access to a BPL modem and control since we had access to a BPL modem and connection.connection. Inside the home a laptop with BPL Inside the home a laptop with BPL interface repeatedly downloading a 40MB+ file.interface repeatedly downloading a 40MB+ file.

All Ham bands within the BPL spectrum were All Ham bands within the BPL spectrum were filtered oufiltered out.t.

Manassas, VA

Interference to BPLInterference to BPL Band Output Power Result Band Output Power Result

80M 40w BPL data transfer 80M 40w BPL data transfer stopped stopped had to be had to be restartedrestarted

40M 40w and 2w BPL data transfer 40M 40w and 2w BPL data transfer stopped stopped had had to be restartedto be restarted

20M 40w BPL data transfer 20M 40w BPL data transfer stopped stopped had to had to be restartedbe restarted

15M 40w BPL data transfer 15M 40w BPL data transfer stopped stopped had to had to be restartedbe restarted

10M 40w BPL data was 10M 40w BPL data was interrupted or slowed. interrupted or slowed.

We could not conclude testing all bands at all available power levels do We could not conclude testing all bands at all available power levels do to time constraints.to time constraints.

CA PUCCA PUC

Public hearing on broadband deployment - Public hearing on broadband deployment - including BPL – Draft Policy * Susan including BPL – Draft Policy * Susan KennedyKennedy

"encourage deployment of BPL by its "encourage deployment of BPL by its electric utilities by providing regulatory electric utilities by providing regulatory certainty in the areas of its affiliate certainty in the areas of its affiliate transaction rules, in the treatment of BPL transaction rules, in the treatment of BPL program expenses and revenues, and program expenses and revenues, and exemption from Section 851 requirements exemption from Section 851 requirements for the use of utility assets."for the use of utility assets."

CA PUC (cont.)CA PUC (cont.) "should adopt this policy framework "should adopt this policy framework

proactively without waiting for an proactively without waiting for an application to be filed by an electric utility application to be filed by an electric utility for a BPL project."for a BPL project."

reply comments recommended the FCC reply comments recommended the FCC "ensure that adequate testing is "ensure that adequate testing is performed and industry standards are performed and industry standards are developed before any deployment takes developed before any deployment takes place." The CPUC also noted "significant place." The CPUC also noted "significant disagreement in the industry over the disagreement in the industry over the level of interference."level of interference."

Dean Straw, N6BV at CA PUCDean Straw, N6BV at CA PUC

No mention of disadvantagesNo mention of disadvantages• Interference to radio receiversInterference to radio receivers• Interference from radio transmittersInterference from radio transmitters• No available bandwidth for expansion, No available bandwidth for expansion,

especially where mitigation is requiredespecially where mitigation is required

CA PUC (cont.)CA PUC (cont.)

We (Hams) are not opposed to We (Hams) are not opposed to broadband internet servicesbroadband internet services

We (Hams) are not opposed to BPLWe (Hams) are not opposed to BPL We (Hams) are opposed to We (Hams) are opposed to

interferenceinterference

CA PUC Reply CommentsCA PUC Reply Comments

Notwithstanding the Draft Report’s enthusiasm about Broadband over Power Lines (BPL), there is nothing to suggest that it will be a viable technological solution to broadband deployment hurdles any time soon.

CA PUC Reply Comments (cont.)CA PUC Reply Comments (cont.)

Even PG&E admits that while BPL may generate a multitude of benefits to both consumers and electricity and telecommunications utilities, it is “both density and distance-sensitive, and therefore, not presently well-suited to serve widely-dispersed rural users.”

Executive SummaryExecutive Summary

““Prescribing an anticipatory form of Prescribing an anticipatory form of regulation could presume that we regulation could presume that we know how technologies and markets know how technologies and markets will evolve. Regulators also want to will evolve. Regulators also want to avoid favoring any one technology avoid favoring any one technology over others and thereby distort the over others and thereby distort the market or impede innovation.” market or impede innovation.”

BPL in WABPL in WA

State Senate committee presentationState Senate committee presentation Chelan/Douglas – Main NetChelan/Douglas – Main Net Spokane – Avista – 2005?Spokane – Avista – 2005? Seattle City Light – evaluating Seattle City Light – evaluating

various technologies various technologies

Good SignsGood Signs

Many trial areas have shut downMany trial areas have shut down• Cedar Rapids, Iowa - deactivated by Cedar Rapids, Iowa - deactivated by

carrier after ham filed interference carrier after ham filed interference complaints. The carrier attempted to complaints. The carrier attempted to resolve the interference issues, but after resolve the interference issues, but after 11 weeks or so, the interference was still 11 weeks or so, the interference was still unresolved. The FCC stepped in and the unresolved. The FCC stepped in and the carrier voluntarily deactivated the carrier voluntarily deactivated the system.system.


• Penn Yan, New York - the system had open Penn Yan, New York - the system had open interference complaints, system integrator interference complaints, system integrator decided to discontinue the BPL trial and decided to discontinue the BPL trial and migrate to wireless.migrate to wireless.

• Raleigh, North Carolina - Carrier announced Raleigh, North Carolina - Carrier announced deactivation of the system which they claim deactivation of the system which they claim was a successful trial. Numerous interference was a successful trial. Numerous interference complaints lodged, however, most of which complaints lodged, however, most of which were unresolved at the time of the were unresolved at the time of the announcement. It's arguable whether this shut announcement. It's arguable whether this shut down was due to interference, but the FCC down was due to interference, but the FCC never officially dismissed the interference never officially dismissed the interference complaints. complaints.


AT&T has withdrawnAT&T has withdrawn Cisco is not funding Amperion’s Cisco is not funding Amperion’s

continuing effortcontinuing effort Some utilities are working in Some utilities are working in

cooperation with local Hamscooperation with local Hams

Ambient Stock Last YearAmbient Stock Last Year

Ambient Stock Last 5 YearsAmbient Stock Last 5 Years

New FCC Chair Kevin J. Martin’s New FCC Chair Kevin J. Martin’s statement at the 14 Oct. R&Ostatement at the 14 Oct. R&O

"Nevertheless, I recognize that Amateur "Nevertheless, I recognize that Amateur radio operators still have concerns that radio operators still have concerns that they will experience interference from BPL they will experience interference from BPL systems. In addition, broadcasters are systems. In addition, broadcasters are concerned that BPL systems will cause concerned that BPL systems will cause interference in the low VHF band. I take interference in the low VHF band. I take these concerns -- as well as the other these concerns -- as well as the other concerns expressed about BPL systems concerns expressed about BPL systems causing interference -- very seriously. I am causing interference -- very seriously. I am confident that the Commission will confident that the Commission will continue to monitor these concerns and continue to monitor these concerns and will take steps, where needed, to address will take steps, where needed, to address interference problems going forward."interference problems going forward."

What is ARRL doing?What is ARRL doing? Maintaining contacts and presence in Maintaining contacts and presence in

standards areastandards area Ed Hare is chair of IEEE C63 ad hoc BPL Ed Hare is chair of IEEE C63 ad hoc BPL

working groupworking group Funding staff and outside filingsFunding staff and outside filings Funding staff and outside studies in BPL areasFunding staff and outside studies in BPL areas Making other affected users aware of BPL Making other affected users aware of BPL

interference issues and encouraging them to interference issues and encouraging them to filefile

Articles in QST and on ARRL web pagesArticles in QST and on ARRL web pages Guidance for local BPL teamsGuidance for local BPL teams

Reconsideration PetitionReconsideration Petition

"a gross policy mistake.“"a gross policy mistake.“ "represents a classic case of "represents a classic case of

prejudgment“prejudgment“ deliberately authorizing "a spectrum deliberately authorizing "a spectrum

pollution source“pollution source“ Powell "tainted this proceeding“Powell "tainted this proceeding“ "late and incomplete" responses to "late and incomplete" responses to

FOIA requestsFOIA requests

What’s Next?What’s Next?

Circuit court of AppealsCircuit court of Appeals Supreme CourtSupreme Court

What Can You Do to Help?What Can You Do to Help?

MembershipMembership Contributions to Spectrum Contributions to Spectrum

Defense FundDefense Fund File comments with FCCFile comments with FCC Right place at the right timeRight place at the right time

Good BPLGood BPL

MicrowaveMicrowave

200 – 400 MHz200 – 400 MHz

Other TechnologiesOther Technologies

WildBlue Satellite - 1WildBlue Satellite - 1stst of 2 launched of 2 launched and will activate early 2005 – 35 spot and will activate early 2005 – 35 spot beams 200 to 250 mi. dia.beams 200 to 250 mi. dia.

Hughes Network Systems – 780 spot Hughes Network Systems – 780 spot beams – 2005beams – 2005

WiFi & WiMaxWiFi & WiMax DSL – speed and distance DSL – speed and distance

improvementsimprovements Fiber to the HomeFiber to the Home

MORE INFORMATIONMORE INFORMATION

Ed Hare, W1RFIEd Hare, W1RFIARRL Laboratory ManagerARRL Laboratory Manager

225 Main St225 Main StNewington,CT 06111Newington,CT 06111

[email protected]@arrl.org860-594-0318860-594-0318

http://www.arrl.org/bplhttp://www.arrl.org/bpl http://www.rarchams.org/bpl.htmhttp://www.rarchams.org/bpl.htm http://www.arrl.org/~ehare/bpl/hyperlinks.htmlhttp://www.arrl.org/~ehare/bpl/hyperlinks.html

questions of the day

Documents