ARRL Citation of Additional Authority Opposing BPL

[W6EM]

On July 8, the ARRL filed a "Citation of Additional Authority" with the FCC to bolster its claims of BPL harmful interference to amateur radio and other services as noted in its already-filed Petition for Reconsideration. #Here is the link to the filing: ARRL's FCC Filling


The League included, in the submittal, the results of BPL field testing from the British OFCOM organization, Britain's equivalent to our FCC. #Interpretation of OFCOM's findings included that BPL notching would be ineffective, and that it would seriously interfere with shortwave broadcasting. #Also, OFCOM concluded that a signal decay standard requirement of 20dB per decade with distance would be appropriate to reasonably reduce the likelihood of interference from ABPL systems. # Not the 40dB as presently specified by the FCC.

Also, the Commission was ‘called on the carpet', as it were, with respect to their own words in the Ultra-Wideband (UWB) proceeding, Second Report and Order and Second Memorandum Opinion and Order, FCC 04-285, in ET Docket 98-153, in which the Commission responded to an assertion from Cingular, Inc., that all RF-emitting devices must be licensed under Section 301 of the Communications Act. #Interestingly, the FCC stated, in effect, a reasonable (sic) reading of Section 301, consistent with Congress' intent and subsequent legislation, would limit the licensing requirement to "any apparatus which transmits enough energy to have a significant potential for causing harmful interference." (Id, pragraph 68).

So, essentially, given that it is an accepted and proven fact that BPL will radiate and will interfere, BPL cannot be permitted to be deployed at the emission limits, as now proposed, as an unlicensed service. #To do so, would be inconsistent with the Commission's stated policy and interpretation of the meaning of Section 301 of the Communications Act in the UWB proceeding.

Sure sounds as though the recent blather over who will keep the BPL database is of little importance, when compared to the ARRL bulletin. #Or, more aptly described, ARRL SILVER BULLET.

Lee
W6EM

[W6EM]

Who knows what they (the FCC) will do, if anything. I suspect they will do nothing.

But, all good fodder for a day or two or three, in court.

Lee
W6EM