Reporting BPL Interference

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 will 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.

Quick Links to this document

Background

Identifying Interference as BPL

Draft BPL complaints

How to file a complaint about BPL

How to file your complaint as a comment in the FCC BPL rulemaking

FCC rules that apply to BPL

More information about BPL

Background:

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 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 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:

http://www.arrl.org/bpl

Several commercial companies are conducting field trials of Broadband over Power Lines (BPL) in locations throughout the United States. Some of these systems may be operating within existing Federal Communications Commission Part 15 limits. However, most have been granted Part 5 experimental licenses by the FCC permitting them to use higher levels. Whether operating under Part 15 or 5, BPL operators are required to cease operation if their systems cause harmful interference. If your HF or VHF operation is experiencing interference from a BPL system, ARRL needs your help to ensure that a report of this interference is made to the involved electric utility company and the FCC.

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 that it is caused by the 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.

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

Draft Complaints

Draft complaints should be e-mailed to rfi@arrl.org or sent to the ARRL RFI Desk, 225 Main St., Newington, CT 06111. Include a recording of the interference, either on cassette tape or to a .wav file. The Laboratory staff can analyze the recording to help identify it as a BPL signal.

Filing Complaints

Complaints should be sent to the FCC, as follows. It is also important that the complaint be filed into the public record in the FCC Notice of Proposed Rulemaking on BPL. This ensures that other FCC staff, utilities and others that are watching the filed comments will have a better understanding of the interference potential of BPL. You can file comments, or view the comments of others, through the FCC’s Electronic Comment Filing System (ECFS) (http://www.fcc.gov/cgb/ecfs/). Under "ECFS Main Links," click on either "Submit a Filing” or “Search for filed comments" and enter "04-37" (including the hyphen but without the quotation marks) in the "Proceeding" field. (Users also may enter other parameters in the form to view, for example, comments filed by a particular individual or entity.)

Then, send your complaints to the following FCC staff. 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.

Sheryl Wilkerson

Email: Sheryl.Wilkerson@fcc.gov

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.

Ensure that your complaint includes your name, call sign, station location, mailing address (if different), telephone number, email address (if any) and a short description of the nature of the interference. This should include information about the frequency, date and time of the interference. Include in your complaint a specific request that the operation of the system cease until the harmful interference has been resolved. The attached information has a template that can be used to generate an interference report. 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 recipient may find the information on Part 15 to be helpful.

The FCC is taking these complaints initially to be informational. That makes it especially important that those FCC Office of Engineering staff listed above receive the copy. 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. It would be appropriate to contact the FCC after a couple of weeks if no attempt has been made to resolve the interference.

Here is an example of an FCC response to a BPL complaint:

From: James Burtle [mailto:James.Burtle@fcc.gov]
Sent: Thursday, August 05, 2004 5:36 AM
To: <deleted>

Subject: Received your complaint

Mr. <Deleted>,

We have received your complaint regarding interference to amateur radio from a Broadband Over Powerline (BPL) experiment. If you have not done so, please send your interference complaint to the BPL system operator in order to afford him/her an opportunity to remedy the problem. We have noted your complaint, but will not be taking action until we are sure that the system operator has been notified and given ample opportunity to fix the problem.

If the interference still exists after you have given the system operator has had ample opportunity to fix the problem please forward your complaint to the FCC. Please include details such as correspondence that you have sent to and received from the operator.

Thank you,

Jim Burtle
Chief, Experimental Licensing Branch
Office of Engineering and Technology
Federal Communications Commission

Notice of Proposed Rulemaking:

The FCC has initiated a Notice of Proposed Rulemaking on BPL. It is also important that your complaint be filed in this proceeding. You can file comments, or view the comments of others, through the FCC’s Electronic Comment Filing System (ECFS) (http://www.fcc.gov/cgb/ecfs/). Under "ECFS Main Links," click on either "Submit a Filing” or “Search for filed comments" and enter "04-37" (including the hyphen but without the quotation marks) in the "Proceeding" field. (Users also may enter other parameters in the form to view, for example, comments filed by a particular individual or entity.) Please take few minutes it will take to also file your complaint as part of the NPRM proceeding. It is important.

Report of Harmful Interference From a Broadband Over Power Line Trial

or Deployment

Name of complainant: ________________________________________________________

Call sign (if applicable):_______________________________________________________

Station location:_____________________________________________________________

Mailing address (if different):___________________________________________________

City, State, Zip:______________________________________________________________

Telephone:________________________ Email:____________________________________

Description of Interference:_____________________________________________________

__________________________________________________________________________

___________________________________________________________________________

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:

Date	Time	Frequency	Receive Mode	Interfering signal strength	Description

Attachment: Excerpt of Part 5 and 15 rules applicable to BPL

TITLE 47--TELECOMMUNICATION

CHAPTER I--FEDERAL COMMUNICATIONS COMMISSION

PART 5--EXPERIMENTAL RADIO SERVICE (OTHER THAN BROADCAST)--Table of Contents

Subpart 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 in

the 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 Contents

Subpart 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

and Information Administration, Department of Commerce, Room 4096, Washington, DC 20230.