ARRL cites 'Additional Authorities' to buttress BPL reconsideration petition

The ARRL has cited the conclusions of a UK study and of the FCC itself to further support its call for the Commission to "reconsider, rescind and re-study" the broadband over power line (BPL) rules it adopted last October.

In its Petition for Reconsideration last February in the BPL proceeding, ET Docket 04-37, the League argued that in permitting unlicensed Part 15 devices such as BPL, the Commission's main obligation is to establish a radiated emission level low enough so that the devices "will predictably not interfere" with licensed services.

"Unless this conclusion can be fairly reached, the Commission has no statutory authority to permit the facilities to operate on an unlicensed basis," the League maintains in a Citation of Additional Authority (Citation) filed July 8. Furthermore, the League says, the FCC itself
affirmed the ARRL's argument in another proceeding.

The League cited a Commission conclusion in last December's Second Report and Order and Second Memorandum Opinion and Order in the Ultra-Wideband
(UWB) proceeding, ET Docket 98-153. The FCC held in its UWB Order that a reasonable reading of Section 301 of the Communications Act would limit licensing to "any apparatus which transmits enough energy to have a significant potential for causing harmful interference." The FCC, the League asserts in its Citation, cannot authorize BPL - although it's an unintentional radiator - due to acknowledged (and field-proven) substantial interference potential to licensed services." The solution, the ARRL said is to establish radiated emission limits at a level that would make the chances of interference negligible.

Accompanying the Citation are studies of BPL systems in Scotland conducted by Ofcom, the UK's telecommunications regulator. Ofcom says concern over signal leakage is one reason for BPL's small UK market share compared with DSL and cable. "Although efficient for their primary purpose, electricity supply cables are not designed, screened or balanced for high frequency use, and in this application they produce significant leakage emissions," the Ofcom study said, adding that the emissions potentially can interfere with radio communication services "including short wave broadcasts."

In its Citation, the ARRL again argues that the FCC "incorrectly rejected" the League's recommendation for a 20 dB extrapolation factor in measuring BPL signal decay on HF based on distance from the signal's source. Instead, the FCC opted to apply the existing - and less stringent - 40 dB/decade factor in Part 15.

"The existing Part 15 standard is clearly inapplicable and underestimates the BPL field strength by up to 11.5 dB," the ARRL said, pointing to the Ofcom studies to support its assertion. The League called the FCC's adopted
40 dB/decade factor "inappropriate." The ARRL also said the Ofcom studies clearly show that notching is ineffective to mitigate interference and that certain BPL systems cannot even meet the FCC's "overly liberal" Part 15 field strength.

The League further noted that the FCC already applies a 20 dB/decade standard to measure signal decay of Part 18 Industrial, Scientific and Medical devices that can operate below 30 MHz.

In last October's BPL Order, the League pointed out, the FCC stated that if new information became available auguring in favor of alternative emission limit/distance standards or extrapolation factors, it would revisit the
issue.

"There is no time like the present," the ARRL urged.

A copy of the ARRL's Citation is on the League's Web site
http://www.arrl.org/tis/info/HTML/plc/filings/BPL-Reconsideration-Citation-
of-Additional-Authority.pdf

Source: ARRL Letter - courtesy of The American Radio Relay League

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