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
