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The FCC Office of Engineering and Technology (OET) will present a draft broadband over power line (BPL) Report and Order to the full Commission when it meets October 14, the ARRL has learned. More than 6100 comments have been filed on the topic since the FCC released its initial Notice of Inquiry in the proceeding, ET Docket 03-104, in April 2003 and a subsequent Notice of Proposed Rule Making (NPRM), ET Docket 04-37, in February of this year. The ARRL so far on this round has taken its concerns regarding Amateur Radio and BPL to three of the Commission's five members. In a meeting this week with FCC Commissioner Jonathan S. Adelstein, an ARRL delegation again asserted that the FCC is pushing the proceeding to a predetermined conclusion with little regard for technical issues.

"Because the FCC has been unwilling to release for public review the results of its own tests and observations of BPL systems, the ARRL has no confidence that the draft Report and Order will be based on sound engineering and believes the rush to adoption is unwarranted and premature," ARRL Chief Executive Officer David Sumner, K1ZZ, said in a follow-up letter to Adelstein. The letter reiterated the League's key points that, it said, "represent the minimum protection" that should be incorporated into the BPL Report and Order prior to Commission adoption.

"Without adequate safeguards, the deployment of BPL systems will result in the pollution and degradation of the unique natural resource of the high-frequency radio spectrum," Sumner said.

The League argued that the R&O include a reduction in the radiated emission limit. The ARRL wants the limit set 30 dB below current Part 15 requirements, which, it says, were established with narrowband point-source radiators in mind. "The record in this proceeding clearly establishes that BPL is not a point-source radiator," the ARRL's letter asserted.

The ARRL pointed out that the National Telecommunications and Information Administration (NTIA) has concluded that at the current Part 15 limit, interference is "likely" to receivers in land vehicles 75 meters from BPL-connected power lines and to fixed stations 460 meters from such power lines.

"Given the number of amateur stations and the fact that they almost invariably are located near power lines, the areas of potential interference at the existing Part 15 limit are clearly too large to permit case-by-case resolution of interference issues," Sumner said. "Based on experience with the very limited test deployments of BPL systems to date, notably in Cedar Rapids, Iowa, Southern Wake County, North Carolina, and Cottonwood, Arizona," the ARRL told Adelstein, "widespread BPL deployment at the existing Part 15 radiated emission limit will result in an unmanageable incidence of interference."

The only way to reduce these areas of potential interference is to reduce the radiated emission limit, the ARRL maintained. Mandatory "notching" of the amateur bands by 30 dB would reduce the probability of interference to amateur stations sufficiently that the remaining interference cases might be resolved on a case-by-case basis. "However," the League added, "such notching would not solve the problem for other radio services."

The ARRL contingent, which included Sumner, ARRL General Counsel Chris Imlay, W3KD, and ARRL Chief Technology Officer Paul Rinaldo, W4RI, decried the FCC's lack of response to issues Sumner raised two months ago regarding a North Carolina Amateur Radio interference complaint. The ARRL representatives carried copies of correspondence questioning a July OET report that essentially gave the Progress Energy Corp BPL field trial a clean bill of health despite continued interference on amateur frequencies.

The League delegation suggested to Adelstein that the OET has swept the North Carolina BPL interference case under the rug and has attempted to discount interference issues in general while overstating the FCC's ability o address them.

Other points the ARRL has stressed in its meetings with Commission members include:

* consider including the NTIA's recommendations to standardize measurement procedures and to require that Access BPL systems be certificated, not merely verified.

* requiring independent confirmation of rules compliance before a BPL system is placed in operation.

* the need for advance public notification of BPL system locations and characteristics, something not included in the NPRM

* performance standards for interference mitigation that would require that interference be terminated immediately upon notification to the operator; and meaningful penalties for non-compliance, including fines.

* require BPL marketers to "give clear notice to potential customers that licensed radio services have priority and that the delivery of broadband service via BPL cannot be guaranteed."

In addition to Adelstein, ARRL representatives have met so far with Commissioners Kevin J. Martin, and Michael J. Copps. The League hopes to meet with the principal advisors to Chairman Michael K. Powell and Commissioner Kathleen Q. Abernathy before the October 7 cutoff for ex parte communications in the proceeding.

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