Hams who believe they are having interference from a BPL system should carefully follow all of the steps in this document to report it to the involved utility company, BPL provider and to the FCC in a way that will help demonstrate the extent of BPL interference and to help the involved parties resolve it. It is important that BPL interference be correctly identified, because it is possible that other sources of noise could be misidentified as BPL. Those may be interference, too, but they would normally be reported and resolved somewhat differently than BPL. Please carefully look at this entire document and follow its steps carefully.
Reporting
interference is critical, especially from the early deployment of a system. The
longer a system operates without interference, the harder it will be to get the
operator to correct it or to shut the system off. Once reported, a licensed user should expect
the BPL operator to correct the interference immediately, or shut the system
down except for brief tests. This is the same approach a licensed station would
use if spurious emissions from a licensed station were causing harmful
interference to another radio service.
Unfortunately, in a number of systems, the local hams are
reluctant to report interference because they have a cordial relationship with
the utility. However, in those cases, most of the time, the utility
doesn't actually do much about the interference, and I think that they get the idea
that it must not be all that bad. Worse, in other areas of the country,
those promoting BPL point to those systems and claim that BPL doesn't cause
interference. They go one step farther in some cases and use those
lack of reports to undermine the reports being made elsewhere.
For that reason, even in cases where there is a good relationship,
ARRL recommends that the interference be reported to the electric utility, with
courtesy carbon copies sent to the FCC. If you do have a good relationship with
your utility, give them a heads up, and explain that the FCC is trying to
decide how to approach BPL and interference resolution, so they need to see
these informational copies. You can also explain that the less than
straightforward approach being used by some BPL proponents elsewhere in the
country also forces the issues in some of those cases where the relationship is
more productive.
Identifying Interference as BPL
How to file a complaint about BPL
You have probably seen some of the ARRL information and news about a new threat to HF amateur operation -- Broadband over Power Line (BPL). BPL uses power lines to conduct high-speed digital signals that use 2-80 MHz to deliver a broadband Internet connection to homes and businesses. Unfortunately, as a side effect, at or near the present levels permitted by FCC rules, the radio-frequency digital signals can and do radiate from power lines at levels that can exceed S9 (very strong signals) to nearby amateur receivers.
You can learn more about BPL technology and its impact on HF communications from the ARRL’s BPL resource page at:
Several commercial companies are conducting
field trials of Broadband over Power Lines (BPL) in locations throughout the
Please take a few minutes and listen to your station to see if you have an increase in noise level. If you do, please follow the instructions in the attached information sheets to verify whether it is caused by a nearby BPL system and to document and report this interference. The BPL industry is claiming that they have had “few” reports of interference from their trials, so each case of interference is an important step to show them and the FCC that BPL can and will cause widespread interference to HF operation.
If you have any questions about BPL or any noise you may be hearing, feel free to contact our ARRL Laboratory staff at ARRL HQ, by email at w1rfi@arrl.org or by telephone at 860-594-0318.
Thank you for your assistance and cooperation. With your help, we can build a body of technical evidence that will protect the amateur service from this source of potential interference. At this point, the FCC is especially interested in reports on how effective or ineffective the “notching” that the BPL systems are experimenting with is working.
BPL is governed by Part 15 of the FCC rules. These rules have a number of provisions intended to protect licensed radio services. Here are the more important ones that apply to BPL interference:
Harmful Interference Defined
§ 15.3 (m) Harmful interference. Any emission,
radiation or induction that endangers the functioning of a radio navigation
service or of other safety services or seriously degrades, obstructs or
repeatedly interrupts a radiocommunications service operating in accordance
with this Chapter.
Harmful
Interference is Prohibited
§ 15.5 General
conditions of operation.
(a)
Persons operating intentional or unintentional radiators shall not be deemed to
have any vested or recognizable right to continued use of any given frequency
by virtue of prior registration or certification of equipment, or, for power
line carrier systems, on the basis of prior notification of use pursuant to §
90.63(g) of this chapter.
(b)
Operation of an intentional, unintentional, or incidental radiator is subject
to the conditions that no harmful interference is caused and that interference
must be accepted that may be caused by the operation of an authorized radio
station, by another intentional or unintentional radiator, by industrial,
scientific and medical (ISM) equipment, or by an incidental radiator.
(c) The
operator of a radio frequency device shall be required to cease operating the
device upon notification by a Commission representative that the device is
causing harmful interference. Operation shall not resume until the condition
causing the harmful interference has been corrected.
BPL operators must resolve harmful interference in a timely manner, in a timeframe agreed to by the BPL operator and the complainant. They are required to cooperate with you. The BPL industry has told the FCC, radio users and the BPL operators that interference can be easily fixed if it happens. This means that “timely” means a matter of days, not weeks or months. If they can’t resolve the interference immediately, you should tell them that you expect them to shut the system down, except for brief tests to assess interference and to assess the effectiveness of the corrections they are making to the system.
The rules state:
Sec. 15.615 General
administrative requirements.
(d) A licensed spectrum user
experiencing harmful interference that is suspected to be caused by an Access
BPL system shall inform the local BPL operator’s contact person designated in
the Access BPL database. The
investigation of the reported interference and the resolution of confirmed
harmful interference from the Access BPL system shall be successfully completed
by the BPL operator within a reasonable time period according to a mutually
acceptable schedule, after the receipt of an interference complaint, in order
to avoid protracted disruptions to licensed services. * * *
In many
cases, BPL systems are small and may not be deployed near fixed stations. In
those cases, however, they have often caused interference to mobile HF
operations in that area. On August 7,
2006, the FCC issued a surprise new rule about mobile interference. This rule
states:
Section 15.611
General technical requirements.
* * * * *
(i) For frequencies below 30 MHz, when a notch filter is used to avoid interference to a
specific frequency band, the Access BPL system
shall be
capable of attenuating emissions within that band to a level at least 20 dB
below the applicable Part 15 limits.
(ii)
For frequencies above 30 MHz, when a notch
filter is used to avoid interference to a specific frequency band, the Access
BPL system
shall be
capable of attenuating emissions within that band to a level at least 10 dB
below the applicable Part 15 limits.
(iii) At
locations where an Access BPL operator attenuates radiated emissions from its
operations in accordance with the above required capabilities,
we will
not require that operator to take further
actions to resolve complaints of harmful interference to mobile
operations.
This rule
basically says that if the system is operating at less than 20 dB lower than
the FCC limits, the FCC will not offer protection to mobile stations receiving
interference.
In most
cases, Amateurs will not have the ability to accurately measure the BPL signal
to determine if it is or is not within these limits. Amateurs who experience harmful interference
to their mobile stations should continue to report that interference to the BPL
operator. It is up to the BPL operator
to either correct the interference or measure it as outlined in the FCC test
procedures to determine that the system is operating below the limits and that
the level of BPL noise in the amateur band are 20 dB below that level at all
locations for which harmful interference is occurring.
This rule
does not affect the right of a fixed, non-mobile station from having harmful
interference at lower levels addressed.
Identifying BPL Signals and Noise
Whether during the experimental trials or ongoing BPL operation, it is necessary that any instances of harmful interference to amateur receiving systems be promptly reported to the local power company and to the FCC. It is important that each interference complaint be a valid case of actual harmful interference. It is possible to misidentify other noise sources as BPL. Filing invalid reports (ie, crying wolf) could be harmful and must be carefully avoided. Amateurs having an interference complaint should preferably have the interference witnessed locally by a technically qualified observer (such as an ARRL Technical Coordinator, Technical Specialist, local-club interference committee), then ask the ARRL Laboratory to review it for technical accuracy and proper form before submitting it to the FCC.
Hams can listen to the sounds of BPL from the ARRL’s video documenting BPL interference in several cities. It can be downloaded from:
http://www.arrl.org/tis/info/HTML/plc/#video
The file is a bit large, but worth the download, even on a dialup.
A description of the nature of the several different types of BPL signals can be heard at:
http://www.arrl.org/news/stories/2004/03/04/1/?nc=1#The
Hams that want to talk with ARRL’s BPL staff can contact Ed Hare, W1RFI@arrl.org, tel: 860-594-0318. In most cases, Ed should be able to help determine whether a suspect noise is or is not BPL.
One important thing that is learned from these trials is how well
interference can be prevented, and mitigated if it happened. These small
installations should be treated the same way as they will be if BPL were
installed in your entire service area, because if this goes as planned, sooner
rather than later, it will be installed near a fixed station that requires more
protection than would be needed for a mobile station. If at this trial stage,
the "solution" is to claim that what is reported isn't really
interference, it will not be possible to determine what can be done in cases
where that claim cannot be the solution.
In general, complaints are more effective if the language they use doesn’t appear “canned.” So you should put your report into your own words. Do be careful with spelling and grammar, though, as such errors detract significantly from the impact of the complaint. You will be addressing your initial complaint to the BPL operator, but, as described later in this document, you will be sending a copy to the FCC. This will help them better understand the impact of BPL on Amateur Radio and will provide a history trail in case the BPL operator is not accurate about your initial contact with them.
In general, a complaint must outline the following information. If it is not
included, the FCC may send it back to the complainant for more information:
See the form below for examples and a recommended format.
1. A description of the interference, including the equipment being interfered with, the frequencies on which interference occurred, and what effect the interference has on your use of the spectrum (that is, does it prevent or degrade reception, interrupt ongoing communications, etc.). As examples, you may have found that the S9 noise caused degradation of your ability to continue a conversation or that it prevented you from making any use of a particular band at all a time when that band was open for worldwide or regional communication.
2. A statement of when the interference started, how often it occurs, and when it was last experienced.
3. The specific geographic location where the interference occurs and (if it is not at your home) the circumstances that result in your routine presence in that area.
4. Your call sign, class of amateur license, and expiration date.
5. Any other information that may be pertinent to the complaint.
Draft complaints should be e-mailed to rfi@arrl.org or
sent to the ARRL RFI Desk,
In
general, to file a complaint that the FCC considers valid, you should provide
them with the following:
The most important part of the
report is the interference, so that should be the most prominent part of your
letter. If you feel that the information on Part 15 is necessary to your
letter, it should be included as an appendix, with a statement that the
utility-company recipient may find the information on Part 15 to be helpful.
Once your complaint is finalized, it should first be sent to your local electric utility or other operator of the BPL system in your area.
Copies should also be sent to the FCC, as follows. You can send them in paper form, or can send them electronically to the email addresses show. Text in an email message, Word document files or Adobe pdf files are all acceptable.
Email list:
Cc your ARRL Division Director
Addresses:
Federal Communications Commission
Spectrum Enforcement Division
Attn: Kathryn Berthot
Email: Kathy.Berthot@fcc.gov
James R. Burtle
Chief, Experimental Licensing Branch
Room 7-A267
E-mail: jburtle@fcc.gov
Federal
Communications Commission
Attn: Riley Hollingsworth
Email: Rholling@fcc.gov
Also, please send a copy of your interference
report the ARRL RFI desk at w1rfi@arrl.org.
If you send copies to others, it is best to do so separately, so the FCC staff receiving your complaint do not mistakenly believe
that they are receiving only a courtesy copy.
After the complaint
In all interference cases, the FCC
generally does not take action until the parties involved have been given a
reasonable opportunity to do what the FCC rules require to resolve the
interference. The FCC generally will respond to your report with an email that
explains that you should contact the operator of the BPL system first. (If you
have followed the steps in this recommendation, you will have done that.) From there, keep records of your
correspondence with the utility or BPL provider, or lack of response from
them. You should copy any information
about this complaint to rfi@arrllorg,
or to the mailing address described for ARRL above.
However, this does NOT mean that
BPL operators do not have to resolve interference promptly. The rules state
that they need to resolve interference promptly, on a schedule that is mutually
acceptable to the parties involved. (See
above.) In the Memorandum and Opinion the FCC released on
August 7, FCC Commissioner Copps said that it was not
acceptable that interference cases involving the Amateur Radio Service were
taking months to resolve.
Once your complaint is filed, you
should expect that the BPL operator will work directly with you to establish a
mutually agreeable timetable to resolve the interference.
Follow-up Complaints
If the BPL operator does not work
with you to set up a mutually agreeable schedule, or substantially does not
meet that schedule, you should then refile your
complaint, but this time as a formal complaint to the FCC. Once you have done so, there is no reason
that the BPL operator would not be able to begin addressing your problem within
a week. If at that point, substantial progress is not being made, you should
again renew your complaint with the FCC, asking them why this system is being
allowed to operate despite the fact that it is causing harmful interference to
licensed users.
Report
of Harmful Interference From a Broadband Over Power
Line Trial
or Deployment
Name of complainant: ________________________________________________________
Call sign (if applicable):_______________________________________________________
Expiration date of license: _____________________________________________________
Station location:_____________________________________________________________
Mailing address (if different):___________________________________________________
City, State, Zip:______________________________________________________________
Telephone:________________________ Email:____________________________________
Description of Interference:_____________________________________________________
__________________________________________________________________________
__________________________________________________________________________
__________________________________________________________________________
___________________________________________________________________________
Frequency(ies) subject to interference:_____________________________________________
Effect of interference on your licensed use of spectrum:________________________________
_____________________________________________________________________________
Examples: Preventing access to spectrum, covering up communications, excessively noisy,
seriously degrading intelligibility, etc.
For mobile or portable operation, explain your presence in the area subject to interference:
_____________________________________________________________________________
_____________________________________________________________________________
Examples: Regularly operate mobile in most areas of your community, visiting others in area and
operating mobile as an incidental part of your presence in the area, etc.
Description of station:___________________________________________________________
___________________________________________________________________________
Receiver(s) affected:____________________________________________________________
Antenna type:_________________________________________________________________
Antenna location:______________________________________________________________
Distance of antenna from own house (feet): __________________________________________
Distance of antenna from neighboring houses (feet): ____________________________________
Distance of antenna from power distribution line or equipment (feet):________________________
Log of interference:
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TITLE 47--TELECOMMUNICATION
CHAPTER I--FEDERAL COMMUNICATIONS COMMISSIONPART 5--EXPERIMENTAL RADIO SERVICE (OTHER THAN BROADCAST)--Table of ContentsSubpart B--Applications and Licenses Sec. 5.85 Frequencies and policy governing their assignment. (a) Stations operating in the Experimental Radio Service may be authorized to use any government or non-government frequency designated inthe Table of Frequency Allocations set forth in part 2 of this chapter, provided that the need for the frequency requested is fully justified by the applicant.
(b) Each frequency or band of frequencies available for assignment to stations in the Experimental Radio Service is available on a shared basis only, and will not be assigned for the exclusive use of any one applicant, and such use may also be restricted to one or more specified geographical areas. Not more than one frequency in a band of frequencies will normally be assigned for the use of a single applicant unless a showing is made demonstrating that need for the assignment of additional frequencies is essential to the proposed program of experimentation. (c) Frequency assignments will be made only on the condition that harmful interference will not be caused to any station operating in accordance with the Table of Frequency Allocation of part 2 of this chapter.
(d) * * * (e) The Commission may, at its discretion, condition any experimental license or STA on the requirement that before commencing operation, the new licensee coordinate its proposed facility with other licensees that may receive interference as a result of the new licensee's operations.
(f) * * *
PART 15--RADIO FREQUENCY DEVICES--Table of ContentsSubpart A--General Sec. 15.5 General conditions of operation. (a) Persons operating intentional or unintentional radiators shall not be deemed to have any vested or recognizable right to continued use of any given frequency by virtue of prior registration or certification of equipment, or, for power line carrier systems, on the basis of prior notification
of use pursuant to Sec. 90.63(g) of this chapter.
(b) Operation of an intentional, unintentional, or incidental radiator is subject to the conditions that no harmful interference is caused and that interference must be accepted that may be caused by the operation of an authorized radio station, by another intentional or unintentional radiator,
by industrial, scientific and medical (ISM) equipment, or by an incidental radiator. (c) The operator of a radio frequency device shall be required to cease operating the device upon notification by a Commission representative that the device is causing harmful interference. Operation shall not resume until the condition causing the harmful interference has been corrected.
(d) * * * Sec. 15.15 General technical requirements. (a) An intentional or unintentional radiator shall be constructed in accordance with good engineering design and manufacturing practice. Emanations from the device shall be suppressed as much as practicable, but in no case shall the emanations exceed the levels specified in these rules.
(b) An intentional or unintentional radiator must be constructed such that the adjustments of any control that is readily accessible by or intended to be accessible to the user will not cause operation of the device in violation of the regulations.
(c) Parties responsible for equipment compliance should note that the limits specified in this part will not prevent harmful interference under all circumstances. Since the operators of part 15 devices are required to cease operation should harmful interference occur to authorized users
of the radio frequency spectrum, the parties responsible for equipment compliance are encouraged to employ the minimum field strength
necessary for communications, to provide greater attenuation of unwanted emissions than required by these regulations, and to advise the
user as to how to resolve harmful interference problems (for example, see Sec. 15.105(b)).
Sec. 15.17 Susceptibility to interference. (a) Parties responsible for equipment compliance are advised to consider the proximity and the high power of non-Government licensed radio stations, such as broadcast, amateur, land mobile, and non-geostationary mobile satellite feeder link earth stations, and of U.S. Government
radio stations, which could include high-powered radar systems, when choosing operating frequencies during the design of their equipment
so as to reduce the susceptibility for receiving harmful interference. Information on non-Government use of the spectrum can be obtained
by consulting the Table of Frequency Allocations in Sec. 2.106 of this chapter.
(b) Information on U.S. Government operations can be obtained by contacting: Director, Spectrum Plans and Policy, National Telecommunications