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| Delivery of Internet services using HF Short Wave on electricity power lines. |
“If only one radio amateur is affected by BPL then the cost to the community is small” says Australian Productivity Commission report.
Delivery of Internet services to homes using HF Short Wave on (BPL) Broadband over Power Lines, Power Line Telecommunications (PLT) or (PLC) Power Line Communications).
ACA say that submissions received may be used to determine its decisions.
Will ACA receive a few or many good submissions from short wave users?
Readers with information on BPL above 30 MHz should share it with the worldwide amateur radio community and also send it to the Australian Communication Authority enquiry into the interference management of Broadband over Power Lines.
My submission to ACA follows-
To- Manager BPL Project Team, Australian Communications Authority (ACA), Australia.
Regarding- The Australian Communications Authority (ACA) discussion paper on: Interference management of Broadband over power line (BPL) applications.
http://internet.aca.gov.au/ACAINTER.131186:STANDARD:2091184344:pc=PC_2845
MANAGEMENT OF INTERFERENCE FROM BPL RECOMMENDATIONS.
BPL OPERATING FREQUENCIES.
1. MEDIUM WAVE AND SHORT WAVE FREQUENCIES ARE UNSUITABLE FOR THE INTERFERENCE MANAGEMENT OF BPL APPLICATIONS:
a. The largest numerical users of 1.7 to 30 MHz frequencies (Amateur radio stations) are located inside the residential environment and next to power lines. The current proposal would radiate BPL electromagnetic radiation that has been shown to block the use of radio communication equipment in the frequencies proposed to be used by BPL from 1.7 to 30 MHz. (See Appendix 1 and 2).
b. These frequencies are used for “free” national and international communications using the earth’s Ionosphere. This is a naturally occurring gift from nature to all mankind and womankind that exists in no other part of the radio spectrum. To spoil it by dumping unwanted electromagnetic radiation so that current and future generations can no longer use it is like dumping waste into natures atmosphere, rivers and oceans so that they too become unusable.
c. The removal this year of the Morse code requirement and a simplified theory requirement for the new beginner amateur radio license will bring free national and international short wave radio communication and training in easy reach of every Australian citizen for the first time ever.
These thousands of new amateur radio stations and current users must be protected from substantial BPL radio frequency interference.
2. FREQUENCIES ABOVE 30 MHZ ARE MORE SUITABLE FOR THE INTERFERENCE MANAGEMENT OF BPL APPLICATIONS WORLDWIDE:
a. Frequencies above 30 MHz are used for short distance purposes.
b. The possibility of BPL interference is dramatically reduced.
3. IN AUSTRALIA THE FREQUENCIES FROM 31 TO 45 MHZ AND FROM 71 TO 85 MHZ ARE ESPECIALLY MORE SUITABLE FOR THE INTERFERENCE MANAGEMENT OF BPL APPLICATIONS:
Worldwide there are no amateur radio frequencies in this part of the radio spectrum. This is ensured by excluding use of the 50 to 54 MHz International amateur band and the European and African 70 to 70.5MHz amateur bands.
The 31 to 45 MHz band.
a. In Australia users of the 31 MHz to 45 MHz band normally use small antennas for short range devises. They are not as greatly affected as are radio amateurs who use large antennas for long distance weak signal communication.
b. Fewer licensed radio communications users are located in Australia on the 31 to 45 MHz band.
c. FM users use noise muting and strong signals from repeater systems that may minimise BPL interference problems. They are not as greatly affected as radio amateurs who use large antennas for long distance weak signal communication.
d. None licensed consumer products that use this band are widely available for use outside this frequency band.
The 71 to 85 MHz band.
a. In Australia users of the 71 MHz to 85 MHz band usually operate on FM and would not be as greatly affected as are radio amateurs who operate below 30 MHz for national and international communication.
b. FM users use noise muting and strong signals from repeater systems that may minimise BPL problems. They are not as greatly affected as are radio amateurs who use large antennas for long distance weak signal communication.
c. Existing licensed radio communication users in the 31 to 45 Mhz and the 71 to 85 MHz bands are able to move if necessary to other bands. Use of this radio band has been decreasing with licensed users moving into the high band VHF (Very High Frequency) and UHF (Ultra High Frequency).
d. Protected services in the 31 to 45 MHz and the 71 to 85 MHz bands can continue to be protected from BPL interference.
4. AUSTRALIA SHOULD TAKE A LEADING ROLE BY RULING OUT THE USE OF BPL ON SHORT WAVE AND SEEK TRAILS ABOVE 30 MHZ FOR BPL APPLICATIONS.
a. I note that ACA provide the alternate possibility of doing nothing and watching international developments.
b. Ruling out short wave for BPL and encouraging trials on frequencies above 30 MHz will contribute to developments worldwide given the adverse interference results that are being replicated in Australia and overseas below 30 MHz.
This gives BPL a direction in which to conduct new trials to demonstrate that what is not feasible below 30 MHz it can make feasible above 30 MHz.
c. Future developments by Motorola USA towards amateur radio interference free BPL outlined in Appendix 4 and Appendix 5 can be applied above 30 MHz.
The ACA paper said,
a. “The ACA is unaware of any commercially available access BPL products capable of operating above the frequency of 42 MHz, but would be interested in information about products that operate above this frequency”.
b. “Most BPL products operate within the frequency range 1.7 MHz to 30 MHz, although submissions to the United States (US) BPL inquiry indicated equipment could operate in frequencies up to 80 MHz”.
BPL EQUIPMENT WOULD BE MANUFACTURED FOR WHAT EVER FREQUENCY RANGE AUSTRALIA REQUIRED. (See appendix 5).
BPL is a developing idea for which trials have shown the real problems caused when it is used in residential populated areas on the tested frequencies of 1.7 to 30 MHz.
5. BPL PROVIDERS SHOULD BE DIRECTED BY ACA AT THIS EARLY STAGE OF DEVELOPMENT TO SEEK BPL EQUIPMENT FOR TRIALS IN THE 31 MHZ TO 45 MHZ AND 71 TO 85 MHZ RADIO SPECTRUM.
Interference management will be enhanced because:
a. BPL will not affect national and international communications and
b. This will avoid substantial disruption to the radio spectrum below 30 MHz that is poised to explode in activity in Australia’s residential areas with the new beginner amateur radio license.
BPL RADIO FREQUENCY INTERFERENCE.
6. BPL SYSTEMS THAT LEAK RADIATION INTO POPULATED RESIDENTIAL ENVIRONMENTS AND CAUSE RADIO FREQUENCY INTERFERENCE MUST NOT DO SO ON AMATEUR RADIO FREQUENCIES (LEAKAGE MUST BE ON COMMERCIAL FREQUENCIES)
And
7. LICENSED AMATEUR RADIO STATIONS BE PROTECTED FROM SUBSTANTIAL INTERFERENCE CAUSED BY BPL RADIO FREQUENCY INTERFERENCE.
The Industrial, scientific, medical, commercial, fixed and mobile radio spectrum are allocated for commercial moneymaking activities.
BPL should not be permitted to use amateur frequencies. This radio spectrum is allocated worldwide by the United Nations for the use of citizens worldwide free of interference from commercial users.
The new beginner amateur radio license to be introduced this year will allow rapid take up of 1.7 to 30 MHz short wave HF amateur radio frequencies by thousands of Australian citizens because of the removal of the Morse code and simplified theory examination.
Most citizens are in residential areas next to power lines.
BPL is a commercial user of radio spectrum and should be required to operate on frequencies allocated for commercial use.
Amateur radio frequencies are an international park for non-commercial activities where all the citizens of the world meet and talk for free.
BPL radio interference to amateur radio frequencies is the same as a commercial operator who dumps waste into a natural resource making it unusable for citizens both now and into the future.
The ability of BPL providers to keep changing the frequency of their equipment might be a source of never ending problems for residential amateur radio stations. Interference today is gone tomorrow and back again the next day because the BPL provider has no frequency restriction, no requirement to stay in one area of the spectrum and no required knowledge to understand the consequences of making frequency changes. This is a major interference management concern.
8. THE FEDERAL COMMUNICATIONS COMMISSION (FCC) PART 15 STANDARDS WITH INTERFERENCE MANAGEMENT HAS A MIXED RECORD OF ASSISTANCE TO USA AMATEUR RADIO STATIONS.
A standard on its own is not satisfactory because there may be situations where BPL equipment that is part 15 compliant or other standard compliant still causes substantial harmful radio frequency interference that significantly affects the ability to operate an amateur radio station.
This is because the BPL system covers billions of frequencies simultaneously.
The mixed results in managing BPL interference to licensed amateur radio stations in the USA include:
Positive interference management results.
a. Radio interference to ham radio was eliminated when 3 BPL test sites were shut down.
(See appendix 3).
Negative interference management results.
b. FCC failure to respond to a formal ham radio BPL interference complaint.
(See appendix 3).
c. After 1 year and the fourth complaint to FCC a BPL system continues to cause harmful interference to amateur radio.
(See appendix 3).
d. BPL company not forthcoming about interference complaints.
(See appendix 3).
e.ARRL (the national organisation of American radio amateurs) is not happy with FCC inaction to ham radio BPL interference complaints.
(See appendix 3).
f. ARRL conclusion regarding current BPL technology.
(See appendix 3).
Traditional part 15 compliant equipment familiar to the users of frequencies below 30 MHz has operated on a single frequency.
In the case of BPL not one frequency but billions of frequencies will be affected simultaneously making it impossible for amateur stations to escape from such radio frequency interference emissions unless they have protection.
During trials in the USA some BPL tests have been terminated and even completely abandoned in favour of existing none polluting technology because of complaints of radio frequency interference to individual residential amateur radio operators who use frequencies below 30 MHz.
Of all the options to manage interference this option with amateur radio protection is capable of providing rapid resolution when BPL interference affects protected Internationally allocated none commercial amateur radio bands.
If BPL is moved above 30 MHz to the 31 to 45 MHz and 71 to 85 MHz bands where no amateur radio frequencies exist then the interference potential is dramatically reduced. (See appendix 5).
Where BPL systems are operating correctly above 30 MHz outside amateur radio bands then potential for unexpected BPL interference is minimised if the following is noted:
a. BPL equipment or and the associated electricity system hardware can interact in a way that generates unintended frequencies (like spurious emissions and harmonic radiation) that can cause radio frequency interference.
b. Multiple BPL transmitters being used on the one electricity line create mixing of frequencies and can generate unintended frequencies (like spurious emissions and harmonic radiation) that can cause radio frequency interference.
c. Unwanted radio frequencies being generated when 2 different BPL providers are using 2 different electricity providers whose electricity lines come together because they are sharing a common component, hardware or facility.
d. Generation of unwanted frequencies caused by resonance on electricity lines or rectification in a faulty insulator, rusted wire or loose wire.
BPL providers should be required to correct such radio frequency interference that is caused by faults in their equipment and or the associated electricity company hardware.
9. IF RADIO INTERFERENCE OCCURS THEN THE BPL PROVIDER SHOULD MEET THE FULL COST of installing shielded electricity cables, moving electricity cables under ground and any other measures required to remove interference to licensed amateur radio and other licensed radio users.
RF shielded electricity cable should also be installed underground (See appendix 2).
An alternate less expensive interference solution is for BPL providers to install broadband shielded cable in areas where BPL power lines cause interference.
Since BPL is moneymaking use of the radio spectrum it is fair that the funds that BPL generates from its use of the radio spectrum be used to remedy the interference problems it causes to licensed radio users.
ARRL USA describes BPL not as a radio spectrum user but as a radio spectrum polluter and as such it carries the burden to cover the costs to eliminate substantial harmful interference to licensed radio users or terminate BPL interference generating operations. (See appendix 3f).
10. RADIO AMATEURS SHOULD DIRECT BPL INTERFERENCE
COMPLAINTS TO THE ACA.
This will allow ACA to determine:
1. The extent of interference generated by all BPL providers.
2. The extent that each provider resolves problems rapidly and successfully.
3. Develop a database of knowledge on the successful methods to solve BPL interference problems.
4. Identify any successful BPL system.
Other options are not satisfactory because few commercial users have independent complaints resolution processes that are widely known for their rapid assistance to a non-customer. (See appendix 3c and 3d).
The performance of the USA regulator (the FCC) has also been questioned by the ARRL. (See appendix 3b and 3e).
The ACA should examine BPL radio frequency interference complaints from the public and from licensed and none licensed users of the radio spectrum and have the following powers as a condition to permitting any BPL trail or operation (no matter which government agency or minister issues that permission):
1. To order BPL providers to take measures ACA decide is necessary to resolve a radio frequency interference issue especially in protecting licensed radio communication and spectrum services.
2. “Level 1 ACA protection” .
To order BPL providers to immediately stop operation of their interference generating equipment if they are interfering with a (“level 1”) aeronautical, emergency, maritime and other protected service.
3. “Level 2 ACA protection part A” .
To order BPL providers to stop operation of their interference generating equipment if ACA determine that seven (7) days after notifying the BPL provider of substantial interference, that substantial interfere still continues to affect the operation of a (“level 2”) amateur radio protected service.
4. “Level 2 ACA protection part B” .
Where BPL providers indicate that Level 2 part A interference resolution has not been successful and that the BPL provider intends to fund electricity authorities and or interference resolution persons to:
1. Remove existing street and house electricity lines and replace them with radio frequency shielded electricity cable or install shielded broadband cable or
2. Move electricity cable under ground (RF shielded electricity cable should also be installed underground, see appendix 2) or install shielded broadband cable or
3. Any other work needed to remove the radio frequency interference.
Then it will be possible for ACA to allow 21 days in which the said work is to be completed and the substantial interference resolved.
5. BPL interference complaints from the general public.
ACA should record BPL interference complaints from both the general public and none-licensed users of the radio spectrum so that its data on BPL is as complete as possible.
This information will allow ACA to make further investigations that can provide the public and none-licensed spectrum users with guidance to interference solutions that are found effective.
It is important that information be collected by one agency so that :
1. The impact of this technology is monitored and understood.
2. The information gained can be rapidly analysed and distributed to both BPL providers, those affected by BPL radio frequency interference, the government and to the public.
11. RADIO AMATEURS WITHIN 5 KM OF A BPL TRIAL OR INSTALLATION AND THE WIA BE INFORMED BY MAIL OF POSSIBLE INTERFERENCE TOGETHER WITH DETAILS ON WHOM TO CONTACT TO REMEDY ANY SUBSTANTIAL INTERFERENCE.
An amateur radio call book search via computer based on Postcode should locate all amateur radio operators in the 5 km area. The current 1 km distance is not sufficient when considering the potential interference problems to amateur radio stations that may result from differing BPL systems and installations.
BPL MODULATION.
12. ACA CONDUCT STUDIES TO ADOPT A BPL MODULATION STANDARD THAT:
a. Requires the least spectrum to provide the best broadband services.
b. Causes the least radio frequency interference in terms of the ability to hear a radio conversation in its presence.
c. Might be possible to eliminate from a radio receiver through the use of noise blanker, digital signal processing or other techniques.
d. Might be invisible to a radio receiver through combinations of modulating techniques.
e. BPL providers be required to use equipment with the best interference minimisation techniques.
BPL EQUIPMENT.
13. BPL TRANSMITTER EQUIPMENT BE CERTIFIED TO BE STANDARD COMPLIANT.
Equipment should including techniques that facilitate interference elimination to residential radio communication users.
This equipment should use the modulation that is found to be best able to allow radio communication users to hear a conversation in its presence.
The current frequency attenuation capability of BPL equipment is not sufficient to prevent interference (See appendix 1).
The ability of BPL providers to keep changing the frequency of their equipment might be a source of never ending problems for residential amateur radio stations. Interference today is gone tomorrow and back again the next day because the BPL provider has no frequency restriction or requirement to stay in one area of the spectrum.
This is a major interference management concern.
ADDITIONAL RECOMMENDATIONS.
1.BPL provider’s employ and train licensed amateur radio operators as part of their interference resolution staff so that maximum effort can be directed at resolving all interference problems.
2. ACA employ and train amateur radio operators as extra engineering and clerical staff (if it has insufficient staff to meet demand) as part of their interference resolution staff so that maximum effort can be directed at resolving all interference problems.
3. ACA consider the desirability of requiring BPL providers to have at least one licensed radio amateur in their staff and if this should be a condition on the certification and operation of BPL equipment. This may be useful to control the ability of BPL equipment to be constantly changed from one part of the radio spectrum to another. This problem can cause constant intermittent on going radio frequency interference. Where more than one radio service is affected by BPL interference a person with knowledge on spectrum usage is necessary.
4. ACA needs to consider the position of individual residential radio license holders and protect them from the ability that commercial companies have to delay actions in resolving radio frequency interference problems.
This is a reason for including a system of levels of protection for licensed radio users that is based on the amount of time in which interference problems should be resolved by BPL companies in relation to residential dwellers.
(See appendix 3c).
INTRODUCTION.
I understand that: The purpose of the ACA review is not to discuss the merits of using electricity power lines as a method for delivering broadband services but how to manage the interference. The Australian Communications Authority (ACA) discussion paper says, “the challenge for the ACA is to develop regulatory arrangements that do not unnecessarily inhibit BPL deployments but, at the same time, protect radio communications services from harmful interference”.
Considering that the ACA discussion paper refers to:
The Productivity Commission 2002, (Radio communications, Report no.22, Aus Info, Canberra, Australia) that said, “It is important to note that it is near impossible to totally eliminate all (BPL) interference”.
And considering that the ACA paper said that:
In numerical terms, amateur radio operators form one of the largest user groups of the High Frequency (HF) spectrum in Australia.
And considering that:
1. Most radio amateurs live next to power lines and that
2. BPL companies will wish to provide a 24 hours 7 days a week delivery of Internet and other Broadband services and that
3. Electromagnetic radiation will be emitted from every electricity power line and into every householder wiring and that
4. Radio amateurs living next to electricity power lines might expect to experience interference such as this ACA recording of a BPL signal as heard on short wave radio and that
http://internet.aca.gov.au/ACAINTER.65650:STANDARD:472472370:pc=PC_2846
5. BPL services will be delivered Australia wide.
Some might agree that as ACA reports from the:
Productivity Commission 2002, (Radio communications, Report no.22, Aus Info, Canberra, Australia) “if BPL just affected one household cordless telephone or one amateur radio operator then the cost to the community might be small”.
HOWEVER IT IS CLEAR THAT NOT ONE BUT MANY RADIO AMATEURS WOULD BE AFFECTED BY BPL INTERFERENCE BECAUSE:
1. The current proposal allows BPL to use all amateur radio frequency bands in the short wave radio spectrum from 1.7 to 30 MHz.
http://internet.aca.gov.au/acainterwr/lib284/bpl%20discussion%20paper%20(electronic%20version).doc
2. Wide spread blocking and disruption to amateur short wave radio communications (between 1.7 MHz to 30 MHz) would render national and international High Frequency (HF) communications impossible. This is because most radio amateurs live next to power lines from where unwanted electromagnetic radiation will be leaking 24 hours a day 7 days a week.
3. ACA and radio amateurs are aware of the radio interference problems caused by faulty electricity power pole hardware and the distances that these interfering radio signals can travel along the electricity power line. In the case of BPL it is proposed to feed billions of radio frequency signals directly into electricity wire lines. The electricity wires and 240Volt wiring inside a house act as an antenna and result in unwanted radiation that can interfere with radio communications.
The argument put forward by the Australian Productivity Commission balancing a commercial activity with amateur radio can be addressed in the following terms:
Unlicensed devices are not entitled to operate if they cause harmful interference to licensed radio services, and they cannot be authorised at all, if as current BPL tests show a significant interference potential to licensed services (ARRL).
The Australian Productivity Commission reasoning cannot bypass around this point and do not remove the International requirement to protect amateur radio frequencies from commercial use and specifically radio frequency interference that prevents licensed citizens using those frequencies.
This is especially so if BPL is not a radio spectrum user but a radio spectrum polluter.
COMMUNITY ELECTROMAGNETIC EMISSIONS MANAGEMENT CONCERN.
The BPL interference management question is similar to a nuclear power plant and the question of how to manage the dumping of unwanted waste product.
BPL providers propose to dump unwanted electromagnetic radiation into the environment.
Waste generated by business is normally dumped away from populated centres not directly inside the populated environment.
It is proposed to allow unwanted BPL electromagnetic radiation to radiate from every residential electricity street power line and from internal household 240 Volt wiring.
This will create concern in the general community because unwanted electromagnetic radiation is being pumped into every street and house in the nation.
This concern will be greater than the current electric and magnetic radiation concerns of living near powerlines or near telephone towers.
This is because the BPL process involves injecting electromagnetic radiation 24 hours a day, 7 days into the home of every man, woman and child through household wiring whether they want it or not.
Passenger electronic devises on aircraft should be switched off in case electromagnetic radiation affects aircraft equipment. BPL electromagnetic radiation is a greater level of concern. The Productivity Commission says it is impossible to totally eliminate the potential for BPL interference to electronic equipment. It might be thought to be inappropriate in today’s electronic environment be force all electronic equipment in the populated environment to operate within a BPL permanent 24 hour 7 day electromagnetic field.
Generating radio interference across the radio spectrum by dumping it directly into the immediate populated environment creates an interference management concern.
COMMUNITY INTERFERENCE CONCERNS INCLUDE-
1. Trials of BPL in Australia, Japan, United Kingdom and the USA where ACA (Australia), FCC (USA), Ofcom (UK) and Japanese authorities reported that BPL was unable to meet current electromagnetic standards.
In the case of Australia the discussion paper said “the ACA has undertaken detailed measurements of a number of BPL trials that indicated, the level of radiated field strengths to be in excess of the USA Part 15 rules.
In the case of one trial however, there was capability to make adjustments that lowered the radiated field strengths.
Assessments against the ARPANSA EMR standard indicated the worst case level for a single carrier was 2740 times below the standard”.
See the ACA report on page 12 on-
http://internet.aca.gov.au/acainterwr/lib284/bpl%20discussion%20paper%20(electronic%20version).doc
2. The historical tightening rather than relaxing of electromagnetic standards will make the use of polluting BPL technology difficult to justify to the community especially when every other industry and electromagnetic user has been increasing their electromagnetic compliance standards.
3. BPL has the potential to force all consumer products to increase their electromagnetic immunity.
This means consumers will need to replace any equipment whose operation might suffer from interference caused by BPL electromagnetic radiation.
Consumer products affected by BPL electromagnetic radiation may include anything connected to a radio frequency sensitive telephone line and any electric or electronic product connected to the 240 Volt electricity socket.
4. The Productivity Commission 2002, (Radio communications, Report no.22, Aus Info, Canberra, Australia) said, “It is important to note that it is near impossible to totally eliminate all (BPL) interference”.
THE COMMUNITY CONCERN IS THAT BPL EQUIPMENT, THAT, BY ITS NATURE CREATES WASTE RADIATION, MUST NOT DISRUPT USERS OF COMPLIANT AND OR LICENSED EQUIPMENT BECAUSE:
a. Virtually all city and town people already receive Broadband services in their homes from the telephone line, wireless and satellite as well as in Internet cafes, schools and libraries. As such, the BPL provider might be viewed as a business opportunity for a few that should not be allowed to impact on the enjoyment derived by the citizens use of electric and electronic equipment.
b. Business must operate with out disrupting the community. Cities and towns are not in the middle of the bush. In the bush business has more freedom to cut down trees than would be allowed in populated centres where trees are valued. The city and town is not a mine site where one business can disrupt the years of community work that maintains standards that are acceptable in populated environments. This is why the Australian community has rejected nuclear power despite its great benefit as an alternate electricity producer.
c. Today businesses in populated centres must operate by maintaining the highest community standards.
Broadband is established by multiple providers using multiple non-polluting delivery systems. This means that a new provider is not an essential service and can only succeed in a populated environment by-
1. Conducting business without polluting the environment.
2. Conducting business without disrupting the lives of people in the community.
5. BPL electromagnetic radiation has a potential to enter telephone lines that normally run parallel to electricity wires. BPL therefor has the potential to disrupt household voice communications, Internet telephone dial up and broadband services that are currently delivered over telephone lines.
6. A consequence of the nature of BPL technology is the community security and privacy concern about Internet data being accessible by everyone that is receiving the BPL radio waves.
BPL will carry Internet data and leak it in the form of radio waves along street electricity lines and household power lines.
Any person with a short wave radio receiver can intercept these signals for further processing and monitoring.
Even in cases where a person cannot decode the content it may be possible to monitor the presence or non-presence of household activity remotely through the radio waves being emitted from a householder power line.
7. A concern is the ease of disruption to a BPL service. Just as radiation leaks out it can also get into the BPL system. ARRL have pointed to tests demonstrating that even low levels of radio frequency interference can disrupt BPL transmissions. (ARRL QST, page 75, June 2005).
AMATEUR RADIO INTERFERENCE MANAGEMENT CONCERN.
1. The ACA paper says that in numerical terms, amateur radio operators form one of the largest user groups of High Frequency (HF) Short Wave (SW) spectrum in Australia.
2. Most radio amateurs live next to power lines.
3. Radio Amateurs will be the most affected radio user group because amateur radio stations are located in cities and towns where BPL proposes to operate using amateur radio frequencies between 1.7 to 30 MHz.
4. Access to national and international communications using the short wave frequencies from 1.7 MHz to 30 MHz will never be easier in Australia than when the new beginner amateur radio license is introduced this year.
5. Thousands of new amateur radio stations are expected on short wave radio because the Morse code examination requirement has been eliminated and the theory simplified to allow all Australian citizens rapid entry to short wave communications with the new beginner amateur radio license.
6. The new beginner amateur radio license is designed to make free HF short wave national and international amateur radio communications and training accessible to the entire Australian population.
BPL radio interference could block access for the existing Australian community and to the thousands of new Australian users for whom the beginner license will allow easy access to free short wave radio communications and training.
7. It is probable that in a short time several competing or multi services will share the same electricity power line by using different parts of the entire HF spectrum. In such a case there is little doubt that BPL radio frequency interference would cover the entire HF radio spectrum forcing the end of amateur radio HF operating in cities and towns because all radio amateurs are located next to power lines. (See appendix 1).
8. Amateur radio as well as being a service is also a residential pass time for persons of all ages including the retired.
Radio operators are concerned that they will no longer be able to enjoy their hobby because a commercial company is polluting the radio spectrum.
More of the community is enjoying a well-earned retirement using both the Internet and Amateur radio.
Thousands of new citizens of all ages will soon qualify for the beginners amateur radio license.
BPL is a major residential area interference management concern.
THE ACA HAS THE NATIONAL AND INTERNATIONAL RESPONSIBILITY TO PROTECT LICENSED AMATEUR RADIO OPERATORS FROM BPL RADIO FREQUENCY INTERFERENCE.
1. The ACA paper says that in numerical terms, amateur radio operators form one of the largest user groups of HF spectrum in Australia. As such their frequencies are vital for their continued operation and must be protected from BPL interference especially as most amateur radio operators are next to power lines in cities and towns where BPL will operate 24hours a day, 7 days a week.
2. Exclusive Amateur radio frequency bands are allocated worldwide for the personal use of citizens and not for the use of commercial users. The United Nations regulations have granted to the citizens of the world exclusive frequency bands on which to intercommunicate free from the radio interference caused by commercial moneymaking interests.
3. BPL is a commercial moneymaking interest and should be conducted on frequencies that have been set aside for commercial business activities.
4. The International amateur bands are an International park that has been put aside by the United Nations for none commercial activities. Government, military, radio astronomy, amateur radio, broadcasting, ships, planes and commercial moneymaking users all have their own radio spectrum.
Free communications between citizens must be protected from BPL radio frequency interference that would make short wave radio unusable for the citizens of today and the future.
5. The ACA paper said, “some amateur radio operators are accredited to undertake emergency and safety communications when required”.
Radio amateurs are “on the air” nationally and internationally 24 hours 7 days.
Every radio amateur is ready to provide emergency service and all are ready to help as individual volunteers.
Amateur radio operators can not continue to operate their HF equipment if the power line outside their house is generating radio signals that block or disrupt radio frequencies inside the amateur radio bands.
The result would be a loss of volunteer skilled accredited persons to the country’s emergency services. All licensed radio amateurs provide communications support in emergencies. Emergency communication capability would decrease if radio amateurs were forced off short wave due to BPL radio frequency interference.
The emergency service aspect of Amateur radio was further strengthened at the United Nations World Radio Conference (WRC) in 2003.
The United Nations International Telecommunications Union (ITU) regulation 25.9A says that “Administrations are encouraged to take the necessary steps to allow amateur stations to prepare for and meet communication needs in support of disaster relief".
This requires that ACA maintain the amateur radio service in a condition where amateurs are not forced to leave their HF short wave bands because they where allowed to be swamped by radio frequency interference.
6. The short wave HF band is the only part of the radio spectrum that allows Australia wide and worldwide free communications directly between two radios without needing expensive or complex technologies.
Short wave radio allows citizens to use a natural resource that provides free national and worldwide communications.
Business should not be allowed to dump radio frequency interference that prevents citizens from continuing to use the free short wave amateur radio communication system.
This free communication system has been given to all the licensed citizens of the world by the United Nations and should not be made unusable because of radio frequency interference.
The operation of BPL on amateur radio frequencies is like opening a mine site and telling all the citizens to accept the noise and pollution or leave. It also tells all future citizens- don’t bother coming here because we have removed all the forest, animals and birds and we are mining in a waste land that has been made useless to everyone except to us- the commercial moneymaking company.
Amateur radio is the biggest numerical user of short wave radio frequencies and its use by the citizens of Australia is poised to explode with the new beginner amateur radio license.
BPL must be managed so that the current largest numerical user that is projected to become even larger is protected from BPL radio frequency interference.
7. Most radio amateurs are located in cities and towns and they must be protected from radio frequency interference to allow them current and future use of their United Nations International Telecommunication Union (ITU) allocated amateur short wave radio spectrum.
8. The HF spectrum contains part of the amateur radio satellite service where increase in radio frequency interference could bring a stop to amateur radio satellite communications and development activities on short wave.
Independent projects by NASA USA and China to land man on the moon and Mars and today’s International Space Station and satellite projects require these frequencies to be kept free of interference for citizens to fully participate now and into the future in short wave space research and innovation.
9. Unlicensed devices are not entitled to operate if they cause harmful interference to licensed radio services, and they cannot be authorised at all, if as current BPL tests show a significant interference potential to licensed services (ARRL).
Australian Productivity commission reasoning cannot bypass around this point and do not remove the International requirement to protect amateur radio frequencies from commercial use and specifically radio frequency interference that prevents licensed citizens using those frequencies.
This is especially so if BPL is not a radio spectrum user but a radio spectrum polluter.
SHORT WAVE IS UNSUITABLE FOR BPL.
1. The proposed BPL frequency range from 1.7 to 30 MHz is a unique and irreplaceable part of the radio spectrum that is used worldwide for long distance communications and broadcasting.
BPL interference will effect radio amateurs who are the biggest numerical user of this spectrum. Most radio amateurs live next to power lines in the cities and towns where BPL would operate.
2. It is unnecessary to use the earth’s long distance short wave radio frequencies for a BPL short distance service especially when a more appropriate radio frequency spectrum is available from 31 to 45 MHz and 71 to 85 MHz.
3. Amateur radio operators that live in the cities are communicating across
Australia with isolated Aboriginal communities and remote towns.
This free communication within Australia should not be disrupted.
The citizens use of the short wave radio spectrum that brings the city and the country as well as the city and remote Aboriginal people together must be encouraged to continue and be protected from BPL radio interference.
4. The usefulness and integrity of radio spectrum that exists for the use of licensed citizens today and into the future must be protected from radio frequency interference.
5. International communications that generate tourism, friendship and understanding between Australian citizens and radio amateurs in every country in the world must be allowed to continue free of BPL radio frequency interference.
6. The soon to commence beginners amateur radio license will allow all Australians easy access to the short wave radio spectrum. Most live next to power lines and they need to be protected from BPL radio frequency interference.
7. The developed world has a responsibility for the good and bad outcomes it might make possible through its BPL decisions.
In countries where regulations are not enforced BPL equipment might be able to generate interference over great distances via the naturally occurring ionosphere. Such equipment may wonder on to aeronautical, safety and other protected services.
The result could be a worldwide short wave spectrum that is full of spurious emissions that are hard to locate and correct. The consequences of using high power BPL on long electricity wires and operating on any frequency would be uncontrollable when in the possession of BPL providers with little knowledge or concern for the radio spectrum in countries with little regulatory enforcement.
If inappropriate equipment is not encouraged to be available on the market then this problem will not occur.
8. ITU has put much effort to promote appropriate and interference free use of the short wave radio spectrum.
Short wave radio must be kept in a useable condition for now and for future generations.
Ignoring the consequence for future generations by allowing commercial activities to pollute the short wave frequencies is like putting more and more green house gas into the atmosphere and leaving future generations to live with the consequences of our decisions or none decisions.
9. BPL is offering to provide mostly existing broadband services by using a method that causes interference to unique radio spectrum usage below 30 MHz.
The frequencies below 30 MHz are unique because they allow long distance national and international communications.
It is unnecessary to use the frequencies below 30 MHz when more appropriate frequencies exist above 30 MHz.
Amateur Radio is providing a unique service that requires interference free short wave spectrum for activities that cannot be duplicated elsewhere in the radio spectrum.
BPL activities can be duplicated above 30 MHz.
The Productivity Commission report of 2002.
The ACA reports from the:
Productivity Commission 2002, (Radio communications, Report no.22, Aus Info, Canberra, Australia) that:
1. “It is important to note that it is near impossible to totally eliminate all (BPL) interference”.
2. “If BPL just affected one household cordless telephone or one amateur radio operator then the cost to the community might be small”
This “small cost” should not be on the community it should be on the BPL provider because:
1. BPL is duplicating existing services that are currently being provided by cable, wireless, telephone and satellite and is therefor not an essential service.
2. BPL is to deliver services already delivered by multiple other non-polluting means. (IMPROVEMENTS TO ELECTRICITY MANAGEMENT DO NOT REQUIRE A GIANT BANDWIDTH THAT IS HUNGRY TO ACCESS ALL THE SHORT WAVE RADIO SPECTRUM).
3. BPL is purely a commercial moneymaking proposal.
4. BPL unlike the other providers of broadband services generates radio frequency interference to other spectrum users and so BPL and not the community should pay the cost to remove such interference.
It is concluded that:
To facilitate the interference management from BPL applications the BPL provider should bare the full “small cost” it has estimated to rectify interference problems that its system causes.
If one radio amateur is affected then the BPL commercial operation can cover the full small cost. This might involve replacing street electricity cable with radio frequency shielded electricity cable within 1 km of the residence or other means to solve the interference problem.
An inexpensive solution might be to use shielded cable only instead of electricity lines to deliver broadband in interference affected areas.
If the cost to remove interference becomes too large then the BPL provider must close its BPL radio frequency interference system.
INTERFERENCE COST ESTIMATE FOR BPL SYSTEM OPERATING UNDER 30 MHZ.
1. The lowest cost is the first action in response to an interference complaint.
It involves changing the BPL frequency, lowering the BPL transmitter power level and or attenuating parts of the BPL radio spectrum emission.
Estimated cost to the BPL provider for the purpose of discussion is $ 200 using an in-house engineer for one day (assuming a weekly salary of $ 1000).
2. The highest cost will result if the first action did not remove the interference.
The BPL provider might require conventional electricity street wiring within 1 km to be removed from the vicinity of the amateur radio station.
Replace this wire with special RF shielded electricity cable or installation of RF shielded electricity cable underground or other action to remove the interference problem.
Estimated cost to the BPL provider for discussion purposes is under $ 25,000.
This involves Electricity Company and BPL provider employees working together.
COST TO REMOVE BPL INTERFERENCE TO ONE RADIO AMATEUR.
As the productivity commission report of 2002 suggests this cost is “small” if only one radio amateur is involved.
Since the interference is caused by the commercial operation of the BPL provider it is the BPL provider that should cover the full cost of eliminating the interference.
If one radio amateur is affected the cost is between $ 200 to $ 25,000.
COST TO REMOVE BPL INTERFERENCE TO 300 RADIO AMATEURS.
This may still be a small cost if it is spread across multiple BPL providers who expect revenue in the hundred million dollars.
Lowest cost = 300 x $ 200 = $ 60, 000.
Estimated highest cost to the BPL provider for the purpose of discussion is under
300 x $ 25,000 = $ 7.5 million cost to remove worst case interference.
If 300 radio amateurs are affected the cost is $ 60,000 to $ 7.5 million.
IF THOUSANDS OF RADIO AMATEURS are affected it may still be a small cost for multiple providers if BPL expects profits into the billions of dollars.
A BPL provider can decide when the cost is so high that it must shut down its business.The amount of revenue a BPL provider receives will determine when the cost of removing interference exceeds its profitable income.
.INTERFERENCE COST ESTIMATE FOR BPL SYSTEM OPERATING ABOVE 30 MHZ.
In Australia BPL would be more successful operating on the frequency bands from 31 MHz to 45 MHz and 71 MHz to 85 MHz because these are commercial and not amateur frequencies. This minimises the interference cost associated with the biggest residential user (amateur radio) of radio spectrum under 30MHz.
Amateur radio bands below 30 MHz have unique purposes that cannot be duplicated in other parts of the radio spectrum. One amateur radio band might be used for national communications in the day, another at night, another band allows International communications in the day, another at night or to Africa or to Asia or to the Pacific, USA, Europe or to amateur satellites and so on.
Licensed radio communication users that operate on the commercial bands from 31 to 45 MHz and 71 to 85 MHz bands are able to move to other parts of the radio spectrum such as high band VHF or UHF and obtain the same service.
1. The lowest cost is the first action in response to an interference complaint.It involves changing the BPL frequency, lowering the BPL transmitter power level and or attenuating parts of the BPL radio spectrum emission.
Estimated cost to the BPL provider for the purpose of discussion is $ 200 using an in-house engineer for one day (assuming a weekly salary of $ 1000).
REMOVING INTERFERENCE TO ONE LICENSED RADIO USER IS $ 200.
Most licensed users above 30 MHz operate on one or two frequencies so interference elimination is much easier than below 30 MHz where radio amateurs spread across millions of frequencies within their ITU allocated ham bands).
In the 31 to 45 MHz band.
Existing users with no license short range devices can purchase these for use on other spectrum for under $ 150 if necessary.
Worldwide there are no amateur radio frequency allocations in this band.
In the 71 MHz to 85 MHz band.
In this band fixed and mobile stations use FM that may provide some immunity from interference and vertical aerials that may provide some immunity from horizontal electricity lines.
The cost to relocate a station to another spectrum is under $ 600 per unit.
Worldwide there are no amateur radio frequency allocations in this band.
BPL Interference cost conclusion.
The cost for removing interference caused by BPL is significantly lower if BPL operates on frequencies above 30 MHz.
EUROPEAN COMMISSION DRAFT PROPOSAL.
In relation to BPL the European Commission has mentioned in a draft proposal that “when resolving interference, the Member States should take into account:
1.The importance of the service. 2. Technical aspects and 3. Economic aspects.
http://www.rac.ca/news/bplnews.htm
1. The importance of the amateur radio service.
Amateur radio is a none-replaceable community based service.
The Amateur radio service survives catastrophic destruction in times of disaster because radio operators are not centralised.
This ability is unique among most other radio communication services.
Centralised government and commercial communications facilities are the first to fail in catastrophic disaster situations.
Amateur radio operator skills and equipment are the last line of emergency communications when all other communications has been destroyed.
Skilled citizens that reside through out residential areas train everyday on the air so that they and their equipment are ready 24 hours 7 days to provide assistance worldwide.
Some amateurs are part of disaster and life saving organisations. Others help as licensed and trained individuals who happen to be located where a disaster occurs. Other amateurs find themselves talking to someone seeking emergency assistance or helping to relay or deliver a message to its final destination. Other amateurs volunteer to travel with their equipment and help in disaster zones.
On September 11, 2001 the terrorist attacks in New York by 2 planes that hit the USA twin tower buildings knock out cell phone, Internet, telephone and radio TV broadcast stations in that highly developed nation.
Those communications facilities were centrally located to save economic cost.
Amateur radio operators immediately set up emergency communications at “ground zero”- the twin tower New York disaster site.
With no cell phone, no Internet, no land telephone and no electric power radio amateurs with their battery and generator powered equipment where able to link together emergency services and the concerned worldwide community using radio until business and government where able to restore services.
Amateur radio also known as HAM radio (Helping All Mankind and woMankind radio) was involved in immediate rescue and coordination.
Ham radio provides essential communications when no one else can.
From the confusion of a disaster step forward the amateur radio operators.
Some radio amateurs travelled great distances to help in New York when they realised the scale of the communication need.
Other radio amateurs around the world relayed messages picked up off the Internet and relayed on short wave radio to radio amateurs in New York, helping coordinate aid and relaying heath and welfare messages.
On 26 December 2004 the Indian Ocean Tsunami destroyed cell phones, satellite phones, Internet, land telephones and electricity. Some amateurs died but those who survived used their skills and equipment to provide communications for the authorities when little other communications existed.
Short wave radio was essential to reach the outside world because the disaster destroyed government and commercial communication in several Indian Ocean nations and isolated communities.
On the 13 March 2005 Australian radio amateurs stood ready when Darwin was under cyclone threat. Amateurs recalled how 30 years earlier ham radio was used as the vital communication link to the Federal Government in Canberra after Darwin and all government and commercial communications had been destroyed by cyclone on the 26 December 1974.
From the 4 April 2005 the US Department of Homeland Security conducted a test of the nation’s homeland security system. The goal was to push the system of first responders beyond its limits to find the weak spots.
American Red Cross emergency services Director Mario J. Bruno reported that "Amateur radio operators were there when we needed them, The Red Cross doesn't have to worry if today's fancy telecommunications devices fail, because the amateur radio emergency service will always be there to provide the needed support. Thank you amateur radio emergency service for helping us respond to the largest disaster exercise in the history of the United States”.
The cost of this exercise was $16 million.
The amateur radio service provided to the government was free of charge.
The amateur radio service provides a unique emergency radio service licensed by governments, promoted by the United Nations ITU regulations and operated by volunteer citizens worldwide from their own residential homes.
The value of this free and voluntary service is demonstrated by its unique ability to assist the community when all other communications have been destroyed.
The value of amateur radio in emergency was further strengthened at the United Nations International Telecommunications Union (ITU) World Radio Conference in 2003. The UN adopted regulation 25.9A that says “Administrations are encouraged to take the necessary steps to allow amateur stations to prepare for and meet communication needs in support of disaster relief".
The readiness and effectiveness of the amateur radio service relies on the daily operation of thousands of volunteer amateur radio stations operated by citizens in their own residential homes.
2. TECHNICAL AND 3. ECONOMIC ASPECTS.
The cost for removing interference caused by BPL radio frequency interference is significantly lower if BPL operates outside amateur radio frequencies and above 30 MHz. The economic commercial interest of BPL creates radio frequency interference that can spoil the unique high value free communications enjoyed between the people of the world who use the amateur radio service.
The economic value of ham radio following one catastrophic disaster is priceless.
4. SOCIAL ASPECTS.
This is strangely missing from the European commission draft regarding aspects to consider when resolving BPL interference. Not to consider the social aspect is an attitude that puts commercial interest above social interest.
1. Recreation for the retired.
Activities like amateur radio and the Internet give the elderly the widest scope to keep engaged in the community.
This is relevant because of Australia’s aging population.
2. Career for the young.
There is no age limit for an amateur radio license. Interest in ham radio can provide a career path for the young in electronics, telecommunications and humanitarian work. This will become very relevant with the introduction of the new beginner amateur radio license this year. Appendix 6 shows unique career paths in amateur radio that inspires the young.
3. Training in emergency communication.
All radio amateurs gain and maintain their knowledge “on the air” every day ready to provide free volunteer emergency communications.
4. Promoting city to rural and city to remote Aboriginal communications.
This type of communications between strangers continues to build friendship and respect in Australia and is made possible by short wave radio.
More people in cities, towns and Aboriginal communities will be able to talk together for free with the introduction of the beginner amateur radio license.
5. Developments in amateur radio Telecommunication.
The latest is this year’s design, operation and launch of an amateur radio communication research satellite by India.
AMATEUR RADIO IS NOT LIKE THE INTERNET OR A TELEPHONE.
The Internet, telephone, cell phone and electricity are the first to fail in a major disaster.
The Darwin cyclone, the 911 attack on New York, the Indian Ocean Tsunami and the US Department of Homeland Security show that amateur radio operators are among the few that are always ready when a catastrophic disaster comes.
The value of an amateur radio ready to help the community during any catastrophic disaster is beyond value especially when you consider this is done for free by volunteers. Every radio amateur is such a volunteer.
WHAT IS THE SOCIAL AND ECONOMIC VALUE OF WORLD FRIENDSHIP AND UNDERSTANDING THAT IS PROMOTED WORLDWIDE AND FREE 24 HOURS A DAY 7 DAYS A WEEK ON AMATEUR RADIO?
The social value of amateur radio is immense when you consider:
1. The few free of charge mechanisms that an individual has to contribute from the comfort of their own home to world understanding, peace and acceptance of all people from all countries, religions, age and interests.
2. The effect that each individual radio amateur has on another as they contribute to world understanding, peace and friendship through conversations using a radio transceiver from the comfort of their own home.
Everything people talk about on amateur radio is real.
There are no made-up stories and no “on the air” moneymaking activities.
Radio amateurs use their real name.
Amateur radio operators talk and the licensed citizens of every country can listen and talk back.
Amateur radio has a 100 year tradition of respecting a person’s politics, religion and race reflected in its second name, HAM radio “Helping All Mankind and woMankind” radio.
In 2004 I was in Somalia, East Africa.
Somalia has had no national government for 11 years but has a good telephone and Internet facility.
On my amateur radio I talked with an amateur in the Sudan.
I had never talked with Sudan before. I asked if he would like to talk in Arabic to a Somali next to me.
I later asked my Somali friend what did the radio amateur in Sudan say to you. The answer was “ Look after that man, he is a very good man, please take good care of him.” Imagine a stranger saying that and you can understand the social values that ham radio fosters worldwide between strangers.
Later a radio amateur in Iraq called me and I talked with Iraq for the first time.
5. THE CULTURAL ASPECT.
Also to be considered are cultural values. This aspect is also strangely missing from the European commission draft regarding BPL interference resolution.
Not to consider the cultural aspect is an attitude that puts commercial interest above cultural value.
1. The value one attaches to the rights of all citizens worldwide to continue to enjoy free local, national and international radio communications using the amateur radio frequencies that are specially made available to them by the United Nations International Telecommunication Union (ITU) and
2. The value one attaches to the United Nations ITU prohibition on the commercial use of amateur radio frequencies so that citizens are not harassed by commercial moneymaking activities that intrude into frequencies specifically put aside by the United Nations for the none-commercial use of citizens worldwide.
Conclusion on the Europea |
| Posted by vk2bvs on Sun, May 29, 11:44:51 2005 @ IST 4205 Reads |
| Re: Delivery of Internet services using HF Short Wave on electricity power lines. Posted by vk2bvs on Sat, Jun 11, 17:32:35 2005 @ IST |
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Conclusion on the European Commission draft.
Unlicensed devices are not entitled to operate if they cause harmful interference to licensed radio services, and they cannot be authorised at all, if as current BPL tests show a significant interference potential to licensed services (ARRL).
The European Union draft cannot bypass around this point and does not remove the International requirement to protect amateur radio frequencies from commercial use and specifically radio frequency interference that prevents licensed citizens using those frequencies.
This is especially so if BPL is not a radio spectrum user but a radio spectrum polluter.
APPENDIX 1.
BPL RADIO INTERFERENCE TRIAL RESULTS.
AUSTRALIAN RADIO FREQUENCY STUDIES OF BPL TRAILS.
From BPL trails in 2004 and 2005 Owen Duffy, VK1OD in Australia concluded an amateur radio station (or any other radio user on affected bands) located in a residential environment where a similar BPL system was deployed would not be safely able to transmit at all on the effected bands. This is because of the high risk of interference to possibly active stations that would not be heard through the BPL interference, effectively curtailing all activity on the band by such a station.
http://www.vk1od.net/bpl/MoruyaBplTrial.htm http://www.vk1od.net/bpl/QueanbeyanBplTrial3.htm
BPL radio frequency interference Signal Strength 9 plus 50db.
Radio amateurs were invited to a demonstration of BPL technology by Power Line Communications Group in Queanbeyan (near Canberra), Australia in 2004.
The equipment used in the test saw levels of interference so severe (S9 + 50db outside the premises) that filtering or notching out by only 20 - 30dB will have little effect on reducing its interference potential.
In the opinion of Phil Waite VK2DKN it will be hard to see how cooperation and goodwill between US amateurs and the BPL industry (as recommended by the FCC) will be possible as the interference levels are just so high and so widespread.
Amateur operation in urban areas with BPL access will be impossible.
(WIA Q-NEWS)
http://www.rac.ca/news/bplnews.htm
UK REGULATOR'S STUDY POINTS UP LIMITATIONS OF AMPERION-EQUIPPED BPL TRIAL.
In 2005 the Office of Communications Ofcom (The UK license authority) said BPL equipment deployed in a field trial in Scotland "as tested is not and cannot be FCC Part 15 compliant above 30 MHz.
Ofcom said in its report that a frequency notched PLT (Power line Telecommunications) (same as BPL) electricity line would contribute noise to the HF spectrum at distances as far as 1 km [approximately 0.62 mile] from the line."
Ofcom (The UK license authority) used the FCC (USA license authority standards) as a reference point. The Ofcom investigation also concluded that if Europe adopts Reg TP NB30 radiated emission limits now in effect in Germany, "such adoption would rule out any European deployment" of the Amperion Griffin BPL equipment on which it took measurements in Scotland.
http://www.arrl.org/news/stories/2005/05/11/2/?nc=1
APPENDIX 2.
RESULTS OF BPL RADIO INTERFERENCE FROM UNDER GROUND ELECTRICITY CABLE.
UK CONCLUSION.
In 2005 the Office of Communications Ofcom (The United Kingdom license authority) noted that power lines were not designed shielded or balanced for high-frequency use and can radiate significant leakage even when buried below ground.
http://www.arrl.org/news/stories/2005/05/11/2/?nc=1
BPL INTERFERENCE TRIAL FROM UNDER GROUND ELECTRICITY CABLE IN TASMANIA, AUSTRALIA.
The following is the preliminary finding by Eric, VK7TAS after operating a portable receiver in the immediate area of the Kirksway place April/May 2004 trial.
"Using only a whip antenna and with no AC mains connection, HF amateur allocations were decimated with a wideband buzz and superimposed tic. This was noted in St David’s Park, at a spacing from the installation that few houses in Battery Point or Hobart would exceed.
The domestic electricity distribution system in Battery Point is underground and the distribution cabinets are made from heavy sheet metal.
Underground cables are typically deeply buried and steel armoured.
The circumstances of this trial are not representative of most residential areas.
Moving from Kirksway Place the interference quickly dropped away.
It was possible to hear a New Zealand amateur radio station talking with stations in the Pacific and the ticking was not detectable above local inner city noise.
Reception was impossible next to the BPL houses but with distance things improved greatly.
BPL may have some limited application on industrial and commercial sites with heavily shielded power systems but, BPL is not a suitable technology for residential areas."
http://reast.asn.au/vk7bplwatch.php
APPENDIX 3.
THE FEDERAL COMMUNICATIONS COMMISSION (FCC) PART 15 STANDARDS WITH INTERFERENCE MANAGEMENT HAVE A MIXED RECORD OF ASSISTANCE TO USA AMATEUR RADIO STATIONS.
POSITIVE INTERFERENCE MANAGEMENT RESULTS.
a. RADIO INTERFERENCE TO HAM RADIO WAS ELIMINATED WHEN 3 BPL TEST SITES WERE SHUT DOWN.
Three BPL test sites using Amperion BPL equipment were shut down following amateur radio complaints.
NEGATIVE INTERFERENCE MANAGEMENT RESULTS.
b. FCC FAILURE TO RESPOND TO A FORMAL HAM RADIO BPL INTERFERENCE COMPLAINT.
Operator TXU shut down and voluntary removed its BPL equipment in Irving, Texas, USA on March 2005 only because the American Radio Relay League- ARRL (Australia’s equivalent of the Wireless Institute of Australia- WIA) became involved. This was because the FCC failed to respond to a formal BPL interference complaint from an individual radio amateur.
ARRL called on the system to be shut down and fined for causing harmful interference to amateur radio communication. The BPL operator voluntarily closed the system and removed the BPL equipment.
The negative result was the initial inaction of the FCC to an amateur radio operator’s interference complaint.
c. AFTER 1 YEAR AND THE FOURTH COMPLAINT TO FCC A BPL SYSTEM CONTINUES TO CAUSE HARMFUL INTERFERENCE TO AMATEUR RADIO.
After 1 year of BPL radio interference ARRL asked the FCC for the fourth time in March 2005 to shut down Ambient’s Briarcliff Manor system pilot project in New York without further delay until Ambient addresses interference complaints. The BPL interference continues.
QST magazine page 75, June 2005.
d. BPL COMPANY NOT FORTHCOMING ABOUT INTERFERENCE COMPLAINTS.
ARRL said “Ambient’s apparent tact in making changes in the system after receiving interference complaints and then denying that the interference complaint ever existed is not helpful”.
QST magazine page 75, June 2005.
e. ARRL (THE NATIONAL ORGANISATION OF AMERICAN RADIO AMATEURS) IS NOT HAPPY WITH FCC INACTION TO HAM RADIO BPL INTERFERENCE COMPLAINTS.
ARRL said “The Commissions failure to conduct a thorough investigation of this matter (BPL interference in New York), and the tenor of your February 10, 2005 letter, lead to speculation that the Commission is really not interested in finding the interference that exists at Briarcliff Manor or at other BPL test sites or in enforcing the Part 15 rules”.
QST magazine page 75, June 2005.
f. ARRL CONCLUSION REGARDING CURRENT BPL TECHNOLOGY.
ARRL Chief Executive Officer David Sumner, K1ZZ said BPL has as “an inherent technical flaw”. It is its interference potential that cannot be completely or inexpensively eliminated.
“BPL is not a radio spectrum user. It is a radio spectrum polluter”.
“If the pollution causes harmful interference to an authorised radio station, the BPL system operator has the absolute burden of fixing it, even if that means shutting off the system”.
QST magazine page 75, June 2005.
APPENDIX 4.
Hams encouraged by new Motorola BPL technology.
May 23, 2005.
ARRL, the national association for Amateur Radio, announced today that "The ARRL is pleased to hear Motorola's announcement of its Powerline LV system. This is the first Access Broadband over Power Line (BPL) system that has been designed from the start with radio interference concerns in mind."
http://www.arrl.org/news/stories/2005/05/23/1/?nc=1
(Also see appendix 5).
APPENDIX 5.
ARRL COMMENTS- BPL ON THE AUSTRALIAN POWER DISTRIBUTION SYSTEM AND BPL EQUIPMENT ABOVE 30 MHZ.
American Radio Relay League (ARRL), USA.
Chief Executive Officer,
http://www.arrl.org
26 May 2005.
Dear Sam,
Thank you for sharing your comprehensive document. Good work.
I believe your recommendation to keep BPL out of the HF spectrum and to confine it above 30 MHz is well founded. Yesterday I participated in a panel discussion about BPL interference at the National Spectrum Managers Association Conference in Washington. The commercial representative on the panel was from Current Technologies, which like Motorola does not use HF on the medium voltage lines (Current uses 30-50 MHz) and uses HomePlug modems for the individual customer drops. We found ourselves in 95% agreement.
Managing interference on the customer side of the power transformer may be more difficult in Australia than in the US because each transformer here feeds an average of only 6 or 7 customers.
73,
Dave Sumner, K1ZZ
APPENDIX 6.
UNIQUE CAREER PATHS IN AMATEUR RADIO THAT INSPIRES THE YOUNG.
1. On the 14 March 2005 United States President George Bush nominated Dr. Michael D. Griffin as the new head of the National Aeronautics and Space Administration (NASA).
His hobbies include golf, flying, amateur radio (call sign NR3A), skiing, and scuba diving.
http://academy.gsfc.nasa.gov/1998/html/michael_griffin.html
2. Australian Astronaut Dr Andy Thomas call sign VK5AGR, talks with radio amateurs around the world when he orbits the earth on space missions.
He also enjoys horse riding and jumping, mountain biking, running, wind surfing, and classical guitar playing.
http://www.jsc.nasa.gov/Bios/htmlbios/thomas-a.html
3. Amateur radio on the International Space Station.
Almost every astronaut (USA) and cosmonaut (Russia) holds an amateur radio license.
New astronauts and cosmonauts enjoy qualifying for the ham radio license so that they can use amateur radio in the space shuttle and at the international space station.
Some years ago all communications between a spacecraft and NASA were cut and ham radio was used to re-establish contact by relaying messages between the spacecraft and an Australian amateur radio operator who then telephoned the messages to NASA. Since then ham radio has been considered a last and vital line of NASA emergency space communication. During normal time ham radio is a welcome recreational break for astronauts and cosmonauts who will talk to anyone that can hear them.
http://www.ariss-eu.org
73,
Sam Voron, VK2BVS, 6O0A.
2 Griffith Ave, Roseville, N.S.W., Australia 2069.
E-mail: somaliahamradio@yahoo.com
Tel: 61-2-94171066, 02- 94171066
Web site: http://www.somaliahamradio.8k.com
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