Tally Ho!
----- Original Message -----
From: "Wade Walstrom" <walstrom(a)mchsi.com>
To: "arrl-odv" <arrl-odv(a)reflector.arrl.org>
Sent: Sunday, July 11, 2004 7:29 PM
Subject: [ARRL-ODV:10886] Re: Meetings at FCC on BPL
> Jim Spencer, W0SR, was contacted by someone there, who exactly, I do not
> remember. The Cedar Rapids BPL Steering Committee is assisting where
requested.
>
> 73,
>
> Wade W0EJ
>
> Art Goddard wrote:
>
> > Ed has the info on local hams being interfered with in Cottonwood.
> >
> > 73, Art
> >
> > ----- Original Message -----
> > From: "Sumner, Dave, K1ZZ" <dsumner(a)arrl.org>
> > To: "arrl-odv" <arrl-odv(a)reflector.arrl.org>
> > Sent: Friday, July 09, 2004 10:25 AM
> > Subject: [ARRL-ODV:10867] Re: Meetings at FCC on BPL
> >
> > That sounds fine, Art. Ed is on vacation currently and his schedule
right
> > after the Board meeting is filling up, but we can pursue it bearing that
in
> > mind.
> >
> > Is there a fixed station in Cottonwood that is being interfered with?
That
> > might be helpful although it's not necessary if the levels are far in
excess
> > of the Part 15 limit -- Solomon as much as said they were more concerned
> > about violations of the limit than about interference complaints, which
> > didn't make a lot of sense to me.
> >
> > Dave
> >
> > -----Original Message-----
> > From: Goddard, Art (Dir, SW)
> > Sent: Friday, July 09, 2004 1:14 PM
> > To: arrl-odv
> > Subject: [ARRL-ODV:10865] Re: Meetings at FCC on BPL
> >
> > Dave, an experimental license and Amperion equipment is involved in the
> > Cottonwood, AZ, BPL system. Ed Hare made confirming measurements there
on
> > July 1. The BPL signal was S-7 at a distance of 1-1/2 miles and S-9
+60dB
> > in the neighborhood. Why don't we test OET's assertion that exp's get
more
> > prompt attention ASAP? Getting another case in FCC's lap and another
system
> > shut down soon after Cedar Rapids might help our cause.
> >
> > 73, Art W6XD
> >
> > ----- Original Message -----
> > From: "Sumner, Dave, K1ZZ" <dsumner(a)arrl.org>
> > To: "arrl-odv" <arrl-odv(a)reflector.arrl.org>
> > Sent: Friday, July 09, 2004 8:51 AM
> > Subject: [ARRL-ODV:10862] Meetings at FCC on BPL
> >
> > On Tuesday and Wednesday, July 6-7, Chris Imlay and I had three meetings
on
> > BPL at the FCC (Paul Rinaldo joined us for one of them). Unfortunately,
> > because of scheduling problems (there was an important FCC Open Meeting
on
> > several controversial topics on the 8th) it was necessary to have them
over
> > a two-day period, but we felt it was important to begin meeting with
> > Commissioners as soon as possible after the close of the reply comment
> > period in Docket 04-37.
> > Our first meeting was on Tuesday afternoon with Commissioner Kevin
Martin
> > and his legal advisor on spectrum issues, Sam Feder. We followed a
script
> > Chris and I worked up in advance.
> > We started by giving them each a copy of the ARRL comments and reply
coments
> > in the NPRM proceeding. We emphasized that our only concern is
interference.
> > We're not touting or denigrating any particular technology. We support
> > universal broadband and the principle of a level playing level field for
> > broadband delivery systems, but that must include taking the relative
> > interference potential of the various delivery mechanisms into account.
> > We said that BPL interference is real and has been shown time and time
> > again; it isn't merely hypothetical. We then gave them copies of the
Cedar
> > Rapids BPL Steering Committee technical report that documents the
> > interference at Jim Spencer's station, W0SR. We emphasized that Alliant
> > Energy and Amperion couldn't eliminate the interference after 12 weeks
of
> > trying and that Alliant ultimately cut the test short, in part because
of
> > the interference. We also gave them a thick compilation of the other BPL
> > complaints we knew of that had gone to the FCC in one form or another.
> > We used the Cedar Rapids case to illustrate that the existing
> > rules/procedures/limits provide inadequate protection. The existing
limits
> > are much too high to preclude interference and were set for
short-duration,
> > narrowband emissions, not for long-duration (or constant), broadband
> > emissions. Commissioner Martin said he understood this point, which from
my
> > perspective made the meeting worthwhile by itself because this point is
more
> > easily made in person than in a written argument. We pointed out that
the
> > NTIA says, "Interference risks are high under existing Part 15 limits."
We
> > mentioned that the interference is a problem not just for amateurs, but
also
> > for other HF users and low-band VHF public safety users. We supported
the
> > technical content of the NTIA Phase 1 study and only disupted their
claim
> > that technical solutions to all of the interference issues exist (unless
> > shutting the BPL system off and keeping it off counts as a "solution").
> > Finally, we said that the mitigation procedures proposed by the FCC,
while a
> > step in the right direction, don't go far enough -- the NTIA's
> > recommendations are an improvement -- and do not protect mobile
stations,
> > who need lower emissions limits in order to have meaningful protection.
To
> > be effective, mitigation must be immediate -- but at present
interference
> > complaints are being shunted aside and none has been adjudicated by the
FCC.
> > We left behind copies of my correspondence to Enforcement Bureau Chief
David
> > Solomon about the Cedar Rapids case as well as an advance copy of the
August
> > QST editorial, which addresses what constitutes "harmful" interference.
> > Other than the comment mentioned above, the only feedback we got from
> > Commissioner Martin was that he had not realized interference was such a
> > problem for us. Curiously, Sam Feder asked us what we'd been hearing
from
> > the other offices. We told him this was our first meeting on this round,
so
> > he asked us to give him feedback after we had completed the other
meetings.
> > We got the sense that they knew the Chairman was pushing BPL but they
did
> > not offer any pro-BPL arguments; Commissioner Martin is known for being
> > non-committal in such meetings.
> > Chris and I feel we made effective use of the time, although it's hard
to
> > know how much we accomplished.
> > On Wednesday afternoon we had two meetings. The first, for which Paul
> > Rinaldo (who had just returned from an EMC Symposium in Wroclaw, Poland)
> > joined us, was a combined meeting with the Enforcement Bureau and OET.
We
> > had requested separate meetings but they scheduled it as one meeting.
David
> > Solomon was the ranking FCC official present and brought with him Joe
Casey,
> > Chief of the Spectrum Enforcement Division and Joe's Assistant Chief,
Brian
> > Butler. They were joined by Bruce Franca, one of the Deputy Chiefs of
OET,
> > and Ron Chase, Chief of OET's EMC Division, Technical Analysis Branch.
Anh
> > Wride, the engineer who has been doing most of the work on BPL for OET,
was
> > on the list to attend but did not; we don't know why.
> > In this meeting we went straight to the Cedar Rapids case. I outlined
the
> > history, beginning with Jim Spencer's noticing the interference in his
> > receiver and cruising the neighborhood to find the BPL installers at
work a
> > few blocks away through the 12 weeks that followed until Alliant
terminated
> > the test. We again handed out copies of the Steering Committee report.
David
> > Solomon was defensive, arguing in effect that there hadn't been enough
time
> > following my June 14 "request for intervention on an emergency basis"
for
> > the FCC to investigate and take action before the test was terminated on
> > June 25. Bruce Franca was also a bit combative, saying that there is
"some
> > debate" as to what is harmful interference (which was my cue to bring
out
> > the August editorial). Paul Rinaldo also countered with a technical
> > explanation, which Franca acknowledged was "one way" of looking at it.
> > Solomon's bottom line was that they take this seriously, but that if we
get
> > action in two weeks we ought to be pretty happy. We said that isn't good
> > enough, that if BPL is deployed widely with the existing limits the FCC
will
> > be overwhelmed with interference complaints that it doesn't have the
> > resources to deal with, and that a lower limit coupled with truly
effective
> > mitigation procedures was only reasonable. Perhaps significantly
(although I
> > might be reading too much into this) Franca did not respond with a
defense
> > of the existing limits as he reportedly has in the past.
> > We said we had heard that BPL complaints were being shunted to OET by
the
> > Enforcement Division; their answer was that they "work together" and
that
> > how a complaint is handled depends on whether an Experimental License is
> > involved (which apparently was not the case in Cedar Rapids).
> > Aside from that, we learned that they are working on the repeated
complaints
> > about the Progress Energy test in North Carolina and presumably we
should be
> > hearing something about that soon.
> > Despite our differences, the meeting was cordial and I think we got the
> > point across that Cedar Rapids is the tip of the iceberg and if BPL is
> > widely deployed, the FCC staff who deal with interference complaints are
> > passengers on the Titanic.
> > The third meeting was in Commissioner Michael Copps's office with Paul
> > Margie, his spectrum and legal advisor. Here Chris and I felt we had a
more
> > synmpathetic ear. We went through much the same spiel as with
Commissioner
> > Martin. Margie asked us if we had to choose one interference case for
> > action, which would it be; Chris said that until a couple of weeks ago
it
> > would have been Cedar Rapids, but now it was North Carolina.
Commissioner
> > Copps joined us for a few minutes, Paul advised him of that, and he
agreed
> > that they should get after the Enforcement Bureau about it.
> > After the Board Meeting Chris and I plan as early as possible to
complete
> > the round of meetings with Commissioners Adelstein and Abernathy and
finally
> > with the Chairman (or more probably, with someone in his office). We
> > anticipate the last of these meetings may be a bit frosty.
> > Chris and/or Paul may want to add their own observations.
> > Dave Sumner, K1ZZ
>
>
>
