Subject: [NEXTEL-1] FEMA Takes A Bite Out Of Powerline Broadband

From: [email-masked]
Date: Wed, 17 Dec 2003 19:23:26 -0500

FEMA Takes A Bite Out Of Powerline Broadband
Dec 16, 2003

Until now, the most vocal enemies of what is variously called either powerline
communications (PLC), or broadband over powerline (BPL), have been amateur (or
"ham") radio operators. Led by the American Radio Relay League (ARRL), hams have
used the comment process of the FCC's current inquiry into BPL to complain
loudly and frequently about BPL's potential to create RF interference with
amateur radio.

However, there remained some question as to just how much actual influence all
that shouting would have, compared to the lobbying of equipment vendors and
utilities, and especially the FCC's strong desire to create a third broadband
pipe into the home in service of its vision of intermodal competition.

Now, however, the balance may have shifted a bit. The Federal Emergency
Management Agency (FEMA) doesn't come with a horde of angry hams in its wake but
when it does speak, it carries a good deal more clout. And now, despite having
to file its comments late with a special request to the FCC to accept them
anyway, FEMA has come down sharply on the anti- BPL side of the fence.

It's not clear exactly why FEMA waited until now to file. The agency submitted
reply comments with a request to the FCC to accept and consider them "despite
their lateness," because "the matters set forth in the comments are of great
importance to the national public safety."

FEMA's comments were filed over the signature of Chief Information Officer Barry
West. In them, FEMA expresses "grave concerns" about the impact interference
from unlicensed BPL systems would have on government emergency communications.
FEMA's worries focus on the FEMA National Radio System (FNARS), "the primary
command and control backup communications media for this agency," and a major
component of the federal response plan for major disasters. FNARS transmitters
typically operate in the residential areas FEMA expects would be the most likely
targets of BPL deployments, so the two systems would clearly have to deal with
each other. The agency says it concluded that "introduction of unwanted
interference from the implementation of BPL technology into the high frequency
radio spectrum will result in significant detriments to the operation
of...FNARS."

In support of this conclusion, FEMA cites tests showing that licensed
transmitters would have to increase their signal levels by some +30 dB in order
to compensate for BPL noise. FNARS transmitters "normally conduct communications
with signals that are barely above the ambient noise levels," FEMA notes. Indeed
FNARS transmitters range in output power from 1 kW to 10 kW, which is as high as
they are authorized to go by the National Telecommunications and Information
Administration (NTIA), and even that only is allowed during emergencies. During
normal operations, the system is limited to 3 kW.

In order to achieve the +30 dB signal increase needed to overcome BPL noise,
FEMA argues its 10 kW emergency transmitters would have to increase their power
output to a full megawatt. This is well-beyond their authorized range and the
result, according to FEMA, is that "the interference from PLC would render these
essential communications services useless."
The basic nature of FEMA's argument isn't really any different from the one the
ham radio community has been putting forth for months. Indeed, FEMA even cites
research done by ARRL's Lab Manager Ed Hare regarding the impact on broadband
performance when transmitters overpower the BPL signal to compensate for
interference. However, it's now coming from a government agency - indeed, one
with a mission critical homeland security job. Coming from FEMA, worries about
interference most likely will carry considerably more weight.

On the other hand, this is by no means an immediate deathblow to the technology.
Rather, it means the government is taking the interference question seriously,
and it isn't going to proceed until it's resolved. FEMA has staked out a
conservative position, concluding that "the purported benefits of BPL in terms
of expanded services in certain communications sectors do not appear to outweigh
the benefit to the overall public of HF radio capability as presently used by
government, broadcasting and public-safety users."

However, other agencies are taking a more conciliatory stance. For example, NTIA
itself is searching for ways to make the two technologies more compatible. NTIA
has overall responsibility for some 18,000 federal government transmitters,
including FNARS and other systems that operate in bands that could be affected
by BPL transmissions. Some of these are just as limited in their ability to
tolerate interference, thanks to factors like encryption and automatic link
establishment.

Consequently, NTIA notes in its own comments to the FCC that "NTIA has broad
concerns with radiated emission limits and other measures that may be needed to
protect these systems." However, NTIA also describes BPL as "hold[ing] great
promise as a new source of innovation and competition in the broadband
marketplace," and it encourages the FCC to "move forward expeditiously."

However, NTIA does note that in crafting rules for BPL, "the Commission must be
certain to provide all communications stakeholders with adequate protections
against BPL emissions that may cause unacceptable radio frequency interference."

In other words, full speed ahead, but only if there's a solution to the
interference issues. Toward that end, NTIA says it is undertaking "extensive
modeling, analysis, and measurement efforts for BPL," and it plans to submit the
results to the FCC for consideration.

Of course, the question ultimately becomes whether or not a solution can be
found that will protect these communications systems without hamstringing BPL to
such an extent that it's not viable in the marketplace.
It's also worth examining what effect the basic operation of these systems will
have on BPL. While, as FEMA notes, most consumers are ignorant of this, Part 15
requires their equipment to accept any interference, even if it makes the device
useless. For a technology that already is struggling with technical issues
compared to cable and DSL, that could prove an even more serious problem.

>>Barry West, FEMA, 202/566-1600<<
http://www.telecomweb.com/OTHERVIP/cgi/searchauth.cgi?/search.pbimedia.com/search97cgi/s97_cgi?action=View&VdkVgwKey=%2E%2E%2Fdocuments%2Farchive%2Fbbn%2Fbbn12160301%2Ehtml&DocOffset=1&Collection=archive&&ViewTemplate=new_tweb_view_bbn.hts

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