The Federal Communications Commission (FCC) has recently released their "Notice of Proposed Rule Making" (NPRM) regarding the implementation of a new service to place digital communications for Internet linking over the power line distribution grid that supplies local residences and businesses. On the face of things your first reaction might be, 'gee what a good idea'. From an engineering standpoint however, and from the aspect of how it is going to affect Ham radio as well as other licensed communications services that use the High Frequency (HF), as well as lower Very High Frequency (VHF) radio spectrum, it's a surprisingly bad idea!

It is in fact such a poor idea that when I first heard of it, about a year ago, I thought it would never get off the ground! My belief was that the engineering departments of companies such as Southern California Edison would shoot it down pretty quickly. It seems though that this idea is proceeding and my fear is that, if it is implemented, it will be years or even decades before the situation can be resolved!

This is a valid fear. Other spectrum usage matters have come before the FCC that were at first deemed to be good ideas. It was said that in the example I am thinking of, "new communications technology will be promoted, and only a small portion of one little used Amateur wavelength band will be affected". Well, that was the 220 MHz. issue of several years ago. The new technology referenced was "Amplitude Compandored Single Sideband" or "ACSB". It was deemed that this new usage for data communication for the use of tracking postal package shipping was a good reason to re-allocate 2 Megahertz of spectrum. In the end, "ACSB" was never developed on this portion of spectrum, because it was not feasible, and now only half a dozen or so narrow bandwidth FM channels are used for this service. In other words, a few Kilohertz of spectrum was utilized but, two MegaHertz of spectrum was removed from better usage. No new technology was developed, and appropriate management of spectrum usage was not achieved. I bring this up merely to illustrate the point of what can happen!

If "BPL" is implemented radiated noise levels for the HF and lower VHF radio spectrum will be markedly increased. This would be because the source of this noise is a 'square wave modulated digital signals', laden with harmonic content and emanating from power lines that are in very close proximity, probably within several yards of the location of antenna and radio installations. This will in fact affect not on Amateur radio but also many commercial High Frequency wavelength users. Emergency communications by governmental departments such as FEMA, the Federal Emergency Management Agency would also be negatively impacted.

Looking at this from another perspective, if the source of this noise was an arcing insulator or defective power line transformer or capacitor, the power companies would be constrained under law to fix this and prevent such interference. In this instance they would probably be constrained to say, 'it's not our problem, talk to the company that is providing "BPL" communication. They are the ones that are jamming your radio'! Part of the legislation that in fact needs to be enacted is to implement a mandatory database of such BPL providers.

You see BPL is technically legal now via Part 15 of the FCC rules. This magnitude of usage however would be unprecedented! What also must be written into the rules are severe enforcement penalties for failures to resolve interference complaints in a prompt and equitable manner.

Another engineering constraint that first made me think this would never be implemented is that, because this is an radio frequency (RF) signal conveyed via the power lines -- every transformer that the signal encounters appears to be an RF Choke! An RF choke is a component that because of its high inductance stops an RF signal in its tracks! In practical terms this would mean that every time a pole mounted transformer, buried transformer, or power sub-station is encountered -- the signal must be ducted around this choke point. This would likely be done via fiber optic cable!

To deal with the engineering difficulties that would be encountered in a full scale system would be a daunting task. It would entail such a build-up in infrastructure before the magnitude of the cost was appreciated, it might be deemed that going backwards and dismantling the system could not be tolerated. The correct answer is to develop a better engineered and planned system first, not one that paints the builders into a corner, even as they pursue using it while they are realizing how bad the system is!

Actually I favor a fiber optic approach. Little more difficulty would be entailed each time a 'fiber path' would be installed than would be realized with all the transformers that would have to be by-passed. In fact such installation would be a unitized approach. Each fiber cable could carry much greater bandwidth data, and it would be very secure. Anyone who might wish to "Hack-in" to the BPL system would find that pretty easy. Try climbing a power pole and splicing into a fiber-optic cable, now that's security!

Fiber cables could also be wrapped around existing power lines.
1) They are an insulator.
2) They are very light in weight.
3) They have broad bandwidth
4) They are secure.
5) They pose no greater significant difficulty to install.

How You Should Respond To This Situation

Firstly, if you have already experienced interference, because of some of the initial tests run with this system, you need to document the parameters of this interference. Provide the best technical analysis that you can in terms of noise level before and after. The FCC needs to be aware of these solid facts.

Next if you, like most of us, are merely concerned about the probable havoc that will be unleashed, get your thoughts together! The FCC needs to hear clean, clear, logical assessments of why this is a bad idea. Don't rant and rave, that will do no good. In that case you probably would actually do harm. Clear persuasive cost effective proposals are best! Go to the Electronic Comment Filing System FCC web page at www.fcc.gov/cgb/ecfs/ File your comments regarding ET Docket 04-37

So, fire up your computer. Look also at the ARRL web page at www.arrl.org, look up their article on this issue, and follow the advice and linked forms to put your comments before the FCC and Congress. If we as an organized body respond to this, we will prevail. If we procrastinate and say to ourselves that we can't fill in and 'click send' for such an easy process to fulfill, we will deserve what happens. Ham radio will not be the same!

One further thought, remember what I said about the 220 MHz. band issue, two factors determined that outcome. One was that a completely different FCC staff was in office. The other was that the Ham community by and large did not respond, and thusly we lost the two lower MegHertz of the band! About twenty years earlier in 1972 a different 220 MHz. issue threatened to take one megacycle from the middle of the band; that was the "Class E Citizen Band" proposal. The Ham community jumped on that problem, and we not only kept all five MegaHertz of the band, we were able to buy cheap a bunch of nice "Class E" radios that had already been manufactured and shipped to distribution warehouses! Do the right thing, respond to this threat!

Find below both a sample form, and the actual blank form to e-mail to the FCC

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******** ECFS INSTRUCTIONS FILE - SAMPLE - README **********
******** **********
******** EXPLANATION ONLY - DO NOT SEND IN THIS FILE **********
******** **********
******** REPEAT: DO NOT RE-SEND THIS FILE - IT IS ONLY A SAMPLE
**********
******** **********
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** Email submission rules:
**
** Email submissions should be sent to ecfs@fcc.gov.
** Email submissions will allow printable ASCII text only.
** Email submissions must be contained in the body of the e-mail,
** rather than attachments.
** Email submissions must contain only one document per submission,
** multiple documents will be ignored.
** Email submissions must adhere to the format of the
** Electronic Transmittal Form for Email filings.
**
** Email Filings must be accompanied by information
** containing the ECFS Document Index Terms. For automated processing
** via email, this must be computer readable. For this, you must use
** a free-format, computer-readable form, as described below,
** using SGML tags.
**
** The requested info is to be placed after the text in angle brackets.
**
** The tagged info should be contained on a single line.
** Change the text after the brackets.
**
** <PROCEEDING>, <NAME>, <ADDRESS1>, <CITY>, <STATE>, <ZIP>,
** <DOCUMENT-TYPE>, and <TEXT> are required.
**
** List of DOCUMENT TYPES:
** CO COMMENT
** ER ERRATUM
** MN MOTION
** PR PETITION FOR RECONSIDERATION
** RC REPLY TO COMMENTS
** RL REPLY
** RQ REQUEST
**
** For assistance in using ECFS, please contact: (202) 418-0193 or
** submit an email to: ECFSHELP@fcc.gov.
**
** For suggestions and comments regarding the system design and
** operation, please contact Bill Cline at bcline@fcc.gov or
** (202)418-0267, TTY (202) 418-2555.
**
** NOTE TO OUR INTERNATIONAL USERS SUBMITTING ELECTRONIC
COMMENTS:
** To enable you to file electronically, please complete the required
** "City" and "Zip Code" fileds. Type in "DC" as the state and "00000"
** as the zip.

<PROCEEDING> PUT-DOCKET-NUMBER or RULEMAKING-NUMBER HERE
<DATE> FILED-DATE-IN-MM/DD/YY-FORMAT
<NAME> APPLICANT-OR-PETITIONER-NAME
<ADDRESS1> ADDRESS
<ADDRESS2> ADDRESS
<CITY> CITY
<STATE> TWO-LETTER-STATE-CODE
<ZIP> ZIPCODE
<LAW-FIRM> LAW-FIRM
<ATTORNEY> LAWYER-NAME
<FILE-NUMBER> FILE-NUMBER
<DOCUMENT-TYPE> TWO-LETTER-DOCUMENT-TYPE-CODE (See list of DOCUMENT TYPES)
<PHONE-NUMBER> SENDER-PHONE-NUMBER
<DESCRIPTION> EMAIL-COMMENT
<CONTACT-EMAIL> EMAIL-ADDRESS-RESPONSE-DESTINATION
<TEXT> ACTUAL TEXT OF MESSAGE...
Dear FCC...

** Example 1 (law firm):

<PROCEEDING> 97-21
<DATE> 11/22/97
<NAME> Jane M. Doe
<ADDRESS1> 902 Snyder Lane
<ADDRESS2> Apt. 34
<CITY> Wichita
<STATE> KS
<ZIP> 20530
<LAW-FIRM> Smith & Jones
<ATTORNEY> Robert Smith
<FILE-NUMBER> 2314
<DOCUMENT-TYPE> CO
<PHONE-NUMBER> 410-555-4657
<DESCRIPTION> Email Comment
<CONTACT-EMAIL> jdoe@public.com
<TEXT>

Dear FCC,

Our client, XYZ Company, supports the local-access station WXXX. Please review the
enclosed materials for further explanation. Thanks.

Jane M. Doe
Attorney-At-Law
Smith & Jones

** Example 2 (individual):

<PROCEEDING> 00-221
<DATE> 6/12/01
<NAME> John P. Doe
<ADDRESS1> 123 Kennedy Drive
<ADDRESS2>
<CITY> Newark
<STATE> NJ
<ZIP> 07103
<LAW-FIRM>
<ATTORNEY>
<FILE-NUMBER>
<DOCUMENT-TYPE> RC
<PHONE-NUMBER> 973-555-7893
<DESCRIPTION> Email Comment
<CONTACT-EMAIL> jdoe@commercial.com
<TEXT>Dear FCC,
I don't want to pay more for my phone. Please remove the surcharge and let competition
rule. Thank you.
Joe

ECFS - E-mail Filing
<PROCEEDING>
<DATE>
<NAME>
<ADDRESS1>
<ADDRESS2>
<CITY>
<STATE>
<ZIP>
<LAW-FIRM>
<ATTORNEY>
<FILE-NUMBER>
<DOCUMENT-TYPE>
<PHONE-NUMBER>
<DESCRIPTION>
<CONTACT-EMAIL>
<TEXT>