Broadband over Power Line ARRL Statement Paul L Rinaldo Chief Technology Officer American Radio Relay League Tel: , Fax:

July 20, 2004ARRL-IEEE2 Who is ARRL? Represents 160,000 members, licensed amateur radio operators mostly in USA ARRL is a member society of the International Amateur Radio Union (IARU) which represents 2.6 M amateur radio operators ARRL, IARU active in ITU-R SG 1 studies.

July 20, 2004ARRL-IEEE3 ARRL on Broadband ARRL endorses “universal, affordable access to broadband technology.” BPL has the potential of interfering with radio services, particularly amateur radio Interference has occurred, complaints filed with FCC, have resulted in shut down of systems (e.g. Cedar Rapids, IA)

July 20, 2004ARRL-IEEE4 FCC ET Docket No On Feb 23, FCC released Notice of Proposed Rule Making on BPL. NPRM would permit BPL at Part 15 emission levels for intended emitters, e.g., 30 μV/m measured at 30 m distance. Proposes inadequate mitigation procedures.

July 20, 2004ARRL-IEEE5 NTIA Report NTIA report of April 27 addresses potential interference to federal assignments For low/moderate signals (which describes amateur radio), interference extends to: –75 m to land vehicles, 100 m to boats –460 m to fixed stations –Aircraft 6 km altitude within 40 km of center of a BPL area. ARRL tests are consistent with NTIA’s.

July 20, 2004ARRL-IEEE6 NTIA Lists Protected Frequencies kHz kHz kHz MHz

July 20, 2004ARRL-IEEE7 ARRL Comments FCC’s mitigation provisions are insufficient BPL signals raised noise level >20 dB over ambient –Notching helps but insufficient Separate tests showed that amateur radio signals will disrupt BPL.

July 20, 2004ARRL-IEEE8 ARRL: 0 dBµV/m at 10 m Acceptable Frequency (MHz) Our requirement

July 20, 2004ARRL-IEEE9 Amateur Bands Needing Protection kHz MHz First responders use the band: MHz CB, in residences and vehicles use the band: kHz Broadcast listeners would receive interference as they are also in residential areas kHz MHz (TV) (TV) Add the NTIA list of protected frequencies and there is not much spectrum at MHz left for BPL.

July 20, 2004ARRL-IEEE10 ITU Radio Regulations 4.11 Member States recognize that among frequencies which have long-distance propagation characteristics, those in the bands between 5 and 30 MHz are particularly useful for long-distance communications; they agree to make every possible effort to reserve these bands for such communications… Administrations shall take all practicable and necessary steps to ensure that the operation of electrical apparatus or installations of any kind, including power and telecommunication distribution networks, but excluding ISM, does not cause harmful interference to a radiocommunication service…

July 20, 2004ARRL-IEEE11 Conclusion Unless BPL emissions reduced to 0 dBµV/m at 10 m, amateur radio would receive harmful interference.