Thought I'd pass this on since the BPL seems to be seen as inevitable by
some out there....
FEMA TO FCC: BPL WILL 'SEVERELY IMPAIR' MISSION ESSENTIAL HF OPERATIONS
Expressing "grave concerns" about likely interference from unlicensed
Broadband over Power Line (BPL) systems, the Federal Emergency Management
Agency (FEMA) has told the FCC that BPL could "severely impair FEMA's
mission-essential HF radio operations in areas serviced by BPL technology."
FEMA filed comments December 4 in response to last April's FCC BPL
Notice of Inquiry, ET Docket 03-104. FEMA expressed primary concern over
BPL's potential impact on the FEMA National Radio System (FNARS), which
operates on HF and serves as the agency's primary command and control backup
medium as part of the Federal Response Plan.
"FEMA has concluded that introduction of unwanted interference from
the implementation of BPL technology into the high frequency radio spectrum
will result in significant detriment to the operation of FEMA radio systems
such as FNARS," FEMA's comments assert. "FNARS radio operators normally
conduct communications with signals that are barely above the ambient noise
levels."
FEMA further noted that FNARS HF stations typically are in residential
areas of the sort that BPL -- a form of power line carrier (PLC) technology
-- might serve. BPL also could render such "essential communications
services" as the Radio Amateur Civil Emergency Service (RACES), the Military
Affiliate Radio System (MARS) and the Civil Air Patrol (CAP) useless, FEMA
said.
FEMA and ARRL last year signed a Memorandum of Understanding that
focuses on how Amateur Radio personnel may coordinate with the agency to
support emergency communications functions.
Calling the HF spectrum "an invaluable and irreplaceable public safety
resource," FEMA said there's no current alternative to HF in terms of
meeting national security and emergency preparedness requirements at the
national, state and local levels. The agency recommended beefing up the
FCC's Part 15 rules to ensure no increase in interference levels to existing
FCC or NTIA-licensed communication systems, "because any noise increase
inevitably would diminish the ability to maintain essential communications,"
FEMA said, and would "directly impair the safety of life and property."
The BPL interference situation is reciprocal, FEMA noted, citing
"Interference to PLC systems from Amateur Radio Operation". That paper
points out that Amateur Radio transmitters likely would interfere with BPL
systems. BPL users likewise would experience service interruptions when its
transmitters "overpower the signal levels expected by BPL modems," FEMA
predicted.
Broadband over Power Line (BPL) systems would use low and
medium-voltage power lines like these to deliver broadband Internet service
to homes and businesses.
FCC adoption of proposals to encourage widespread development and deployment
of BPL also could result in consumer confusion regarding who would resolve
interference issues and how.
FEMA said it believes licensed radio services "will be perceived by
consumers as responsible for the interference, since most consumers do not
understand that their unlicensed Part 15 devices 'must accept any
interference received, including interference that may cause undesired
operation.'"
"The purported benefits of BPL in terms of expanded services in
certain communications sectors do not appear to outweigh the benefit to the
overall public of HF radio capability as presently used by government,
broadcasting and public safety users," FEMA concluded.
FEMA Chief Information Officer Barry C. West, who filed the comments
on the agency's behalf, characterized the issues it raises as being "of
great importance to the national public safety."
Because FEMA now is part of the Department of Homeland Security, its
perspectives on BPL could carry substantial weight at the FCC, which may
issue a Notice of Proposed Rule Making as early as February.
The ARRL announced last week that it plans to complete an independent
BPL engineering study within a couple of months. The study will explore how
BPL might affect HF and low-VHF amateur operation as well as how Amateur
Radio operation could affect BPL systems.
Sorry if this is a duplication of information to some of you, but I
thought that others might be interested in seeing it. I work with FEMA
in emergency comms as a sideline activity and figured they'd weigh in
with some hefty remarks. I'm pleased with the emphasis they are placing
on the interference issues as well as the critical need to keep HF as a
viable emergency communications spectrum. With Homeland Security issues
being of paramount importance these days (sorta like Civil Defense was
to some of the more buzzardish- listmembers) it won't be a simple issue
of "big business tromping on the poor little hams" , but more an issue
of putting the security of the country first.
Not that this is guaranteed to stop BPL mind you, but it certainly adds
a lot more weight to the arguments we've been making for so long.
de Todd/'Boomer' KA1KAQ
