Subject: [NEXTEL-1] Alan Dixon On the Matter of Inquiry Regarding Carrier Current Systems, including Broadband over Power Line Systems (BPL)

From: [email-masked]
Date: Wed, 05 May 2004 02:12:12 -0400

Before the Federal Communications Commission
Washington, DC 20554
In the Matter of Inquiry Regarding Carrier Current Systems, including
Broadband over Power Line Systems (BPL)

ET Docket No. 04-37
ET Docket No. 03-104
FCC 04-29

COMMENTS TO NOTICE OF PROPOSED RULE MAKING
GREETINGS:

As so aptly reported by numerous commenters in this, the above-captioned
proceeding, the proposed Broadband over Power Line carrier current
systems have clear potential to disrupt wireless communications across
the entire High Frequency (HF) spectrum, along with certain other bands.
While substantial attention has been most rightly directed toward
protecting licensed Amateur Radio Service operations (see ARRL
comments), it is paramount to note that all HF spectrum (3 to 30 MHz)
needs to be likewise protected from any and all spectrum pollution.

One particular authorized radio service of vital concern within the HF
spectrum is the 27
MHz Citizens Band (CB) Radio Service (47 CFR Part 95D). Contrary to what
many would
assume to constitute conventional wisdom, CB radio product acquisition
and use remains vibrant
today, and even more so over the past several years! I cannot emphasize
enough that the role of
CB radio in present times is not to be underestimated. One of the most
often misunderstood
subjects, a matter close to the heart of tens of millions of wireless
consumers, is the present state
of 27 MHz CB radio popularity and usage. Whether or not any of us are
old enough to
remember the explosive popularity of CB radio during the 1970’s, nearly
everyone even remotely familiar with CB has some knowledge of that
decade’s greatest fad. Fads, by definition, come and go. Nevertheless,
sustained popularity of CB radio has been steadily increasing since the
close of the 1970’s.

DISCUSSION

When the CB craze of the seventies faded just as rapidly as it had
arrived, many people
both within and without the CB world summarily concluded that CB radio
was either dead or
dying. Aside from the fad though, how has CB radio popularity fared over
the last two-plus
decades? Even disregarding the entire CB craze phenomenon of the
mid-1970’s, a number of
communications volunteers and hobbyists, as well as occupational users
and professionals, seem
to feel that interest in CB radio has been on a steady decline over the
past twenty years. But, is
this assumption valid?

For the many of us who lived the CB fad in the mid-1970’s, it is an
all-to-easy, though not at all accurate, conclusion. In 1976, all 23 CB
channels (at that time) were loaded with traffic, in nearly every part
of the country. The three main trucking channels then; 10, 15, and 21,
were busy round-the-clock in even the sparsest areas, if they were
within range of any major highway. Today, professional truckers nearly
everywhere in the US are concentrated on one particular channel: Channel
19. The remainder of the 40 channels we have today enjoy sporadic usage,
including Single-SideBand (SSB) operations on channels 35-40, and
several of the lower channels with AM mode communications. Given that
present-day CB operations are somewhat less frequency-distributed than
in previous times, what is the conclusion to which so many of us are too
quick to jump? Simple: CB radio popularity has been on the decline,
right? No!

Jumping to such a conclusion robs us of seeing some highly relevant
realities. How then, can we see what is really going on? In the course
of my own research over the years, I have noticed an unfortunate dearth
of statistics on CB radio use, sales, manufacturing and imports, or much
else telling. Finally however, in early 2003, I caught up with a group
of researchers at Michigan State University. There, the National Science
Foundation had launched a major multiyear research project on CB radio
popularity in the US, and researchers have completed a preliminary round
of source material gathering. I am privileged that Research Associate
Ms.  Carol Ting has provided rudimentary but statistically significant
figures and qualified observations for my use in compiling facts for
publication, and appearing in this very comments’ Background section.
Much of what Ms. Ting has written, I paraphrase below. What these
researchers have found, we may find quite surprising and enlightening!

BACKGROUND

Just how big was the CB radio fad of the 1970’s? Staggering! CB radio
sales soared from just under two million units in 1974 to over 11
million in 1976. Sales volume began plummeting just a year later,
however. By 1979, annual sales volume had dipped to just under two
million; about the same sales level seen just before the fad.  Research
shows two main factors that spurred the beginning of the CB fad. One was
motorists’ need for fuel availability while on the highway during the
Arab oil embargo. This was tightly coupled with the effect of the
nationwide speed limit of 55 MPH and motorists’ keen interest in related
enforcement activity. The second factor was massive media attention in
newspapers and magazines. Additionally, several country-western genre
songs about truckers’ exploits with CB radio became crossover hits,
assuring air play on nearly every radio station featuring any form of
contemporary music. Television shows and movies rapidly followed suit.
Far more ponderous though, are the snowball effects that brought the fad
to an abrupt
passing. Several factors came into play, each playing into the others.

The first factor was a direct effect of the fad’s rapid onset: Demand
began to outstrip supply. In 1975 alone, some 12 million units were
ordered for retail sale. But only five million were delivered.
Distributors routinely submitted duplicate orders in hopes of receiving
adequate quantities.  New manufacturers entered the business, and
related stock market performance would come to bear a strange
resemblance to the Internet dot-com business boom that would occur two
decades later. This market, that would prove to be sorely optimistic,
caused distributors to amass excessive stockpiles of CB radio units. The
marketing momentum at work in this case spiraled into what economists
describe as a “hog-cycle” supply-demand imbalance which, as researcher
Ting succinctly notes, typically leads to a dramatic market correction.
Another factor resulted from industry lobbying the FCC to authorize more
CB channels.  In the summer of 1976, the Commission responded by
increasing the number of channels from 23 to 40, to be effective January
1, 1977. Sales of new 23-channel CB radios were ordered to cease after
that date, but sales of 40 channel units were not permitted at all prior
to that same date. This literally shortsighted transition policy gave
vendors only five months to clear out their collective massive overstock
of 23-channel sets. An industry panic ensued, causing retailers to dump
their standing inventories into the market at “fire-sale” pricing
levels. Still-new 23-channel radio closeout units were often sold at a
mere 20% of cost, just in time for a heavy Christmas shopping season!
Then, as 1977 dawned, new CB radios with all 40 required channels
typically sold at ten times the most recent pricing of otherwise
comparable new CB radios, sold only a month before.

And, the new 40-channel radios were in relatively short supply. The
hog-cycle effect of
overstocking, coupled with a less-than-optimally timed FCC transition
policy, drove up CB radio
prices (again, relatively) while choking the supply. The result was a
temporary, but steep, plummet in CB radio sales with a supply-and-demand
dynamic that fueled an uncontrolled downward spiral that defined the end
of the CB radio fad era.

CONCLUSIONS

When we step back and look at the bigger picture however, we can see
that, excepting the statistical “spike” caused by the rise and fall of
the CB fad, CB radio popularity has only increased over the ~45 years
that 27 MHz CB radio has existed. That’s right, consumer enthusiasm for
CB radio has steadily increased, ever since 1980, contrary to some
uninformed opinions often given as “fact” by those who no longer have a
stake in consumer CB radio.

Statistical normalization of course, legitimately discounts aberrations
that happen to be
statistically insignificant when considering a larger range of data (a
range several times larger,
that is, than the aberration—the fad spike—in question here.) Therefore,
when we look at the
~45-year span of CB radio history, even just roughly normalizing the
approximately four-year
spread during which the CB fad occurred, we can clearly see that CB
radio sales have increased
nearly steadily over the entire span.

The number of new CB radio units sold topped one million annually, circa
1973. This was up from about 100,000 new units licensed in 1960.
Overall, sales had stepped up to roughly 1.8 million annually by 1980.
Since 1980, new unit sales have steadily increased to just over two
million during 1989. After that time, sales dipped slightly to just
under two million annually until 1995.

After 1995, CB radio annual sales have increased sharply through 1997,
at a rate closely
approximating that of the rise of the CB fad, circa 1973 to 1975! It is
interesting to note that
during these same years of the later 1990’s, the UHF Family Radio
Service (FRS) was
introduced (47 CFR Part 95B). It appears at this point that FRS radio
popularity has
complemented, rather than competed with, 27 MHz CB radio popularity.

To date, there is no real accounting for the tens of millions of CB
radios already in
existence. My understanding is that the Michigan State University
group’s National Science
Foundation study is still in process of investigating the status and
use, as well as disposal of,
previously sold units. Nevertheless, sales of new CB radio sets is an
unimpeachable and solid
measure of accelerating public interest in 27 MHz CB radio. With facts
in hand rather than
anecdotal observation and collective shortsighted individualistic
opinion, we can assert with
confidence that those who claim that CB radio popularity is dead or
dying, simply do not know
whereof they speak. CB radio is unquestionably alive and moreover,
growing at an escalating
rate.

Additionally, we must consider not only consumer demand, but also the
immense number of occupational and professional users of CB radio. The
American Trucking Associations, Inc.  reports that 1.68 million Class 8
(semi-trailer) commercial trucks are on the road nationwide in recent
years.

It is a well-known and undisputed fact that nearly all of them rely on
CB radio 24-byseven, 365, for tactical (operational) communications,
professionally. To date, no alternative wireless products or
technologies are on the horizon to eventually replace truckers’ CB radio
interoperable voice communications. While a growing number of
over-the-road trucks are being equipped with satellite uplinks and
wireless telephones, nothing else supplants CB radio’s local
Push-To-Talk functionality. CB radio is, and will continue to be for
quite some years to come, the primary telematics technology choice among
this class of occupational wireless users.

Given this, the 11-meter band in which 27 MHz CB radio thrives must be
vigorously
protected against interference from unlicensed (Part 15) devices as well
as from any other
services secondary to the CB Radio Service, in or near its spectrum
band. CB radio is by design,
a low-power radio service, since it is intended for local
“short-distance” wireless
communications. Therefore, CB radio’s weak signals need to be especially
carefully protected
from interference. There are more new CB radio sets on the road and in
homes now, than since 1980, by far. Some twenty times the number of new
27 MHz CB radios are being put into use every year, than in had been in
1973, and the present increase is rapidly approaching the number of new
CB radios put on the air in 1975! Fact is, the number of new 11-meter CB
radios being put on the air is not only increasing, but increasing at an
accelerated rate, indicating an upward spiral in popularity and use.

ADDENDUM: HOMELAND DEFENSE

Our nation remains in the midst of the ongoing War on Terrorism, where
preparedness is never an option. Emergency auxiliary communications must
remain high on any individual’s list of mitigation and recovery
necessities. Given my extensive engineering experience in cellular (and
other) networks, I can attest that wireless telephones often enough fail
individual call attempts during widespread emergencies and at mass
casualty incidents. The ill-conceived wireless Priority Access Service
(PAS) program will now further aggravate such delicate situations.
Repeater systems, trunked or conventional, can certainly fail, and
high-power commercial and amateur radio equipment drains batteries far
more quickly than does a simple 4-watt CB radio transmitter.
Additionally, CB radio’s inherent simplex mode of operation makes it
totally independent of repeaters and other wireless network components.
Besides its given low power consumption, there is simply less of
anything to fail during mission-critical local civilian disaster use.

Longtime Radio Emergency Affiliated Communications Teams (REACT)
activist and life member Walt Young of Space Coast REACT in Florida
explains the value of everyday citizen access to CB radio during times
of widespread emergency. “The only saving grace, as I see it, are the
REACT Teams and many Amateur [Radio] Teams across the country who step
up to the plate to assist,” he asserts. During Hurricane Andrew recovery
efforts in Florida in 1992, as well as during the recent Blackout of
2003 (according to preliminary reports), REACT team volunteers were in a
number of instances the only people who could speak wirelessly directly
to the public. Mr. Young notes this supports a Survey his team took at
one of their roadside Safety Breaks. “We asked folks if they had a CB.
About 70 percent of those questioned said yes, it may have been in a
box, a closet, out in the garage, in the trunk of their car,” Young
states.  Regardless of whether or not this CB radio equipment was in
regular use, this majority of consumers surveyed have CB radios
available for emergency use! The public seems to be aware to go hook up
(or re-hook up) these radios as needed for operation, or simply to have
CB radios on standby, during disasters. Young points out that even
without commercial electrical service, any citizen can quickly hook her
or his CB set up to their own car battery and stick an inexpensive
magnetic mount antenna onto the automobile body in order to have instant
emergency wireless communication.

Specifically, Mr. Young explains that during the aftermath of Hurricane
Andrew, it
turned out that REACT communications volunteers—with their mobile CB
radio installations—
were the only mitigation personnel able to communicate with the
thousands of trucks coming
into Florida with relief supplies. Young tells us that none of the
emergency radio operators there
at that moment had CB radio, or were in a position to utilize that mode
so, the local “Emergency
Management [Agency]...called us [REACT]. We went out to the rest area
just south of Malabar
[on Interstate 95] and set up our communications. We would give info for
truckers to go to a
staging area set up off the West Palm exit where they would then be
dispatched to needed areas, rather than just going in blind and not
knowing where to go...Those truckers really did appreciate it. They had
no idea where they were going or where to unload. We ran it [staging
area operations] for several days until the traffic slowed.”

Young concludes, “In addition, because of the roads being closed we had
a packed rest area of people who could not get home. We ended up getting
food donated and gave it to the people ‘camping’ there.” The Hurricane
Andrew incident, “...also put us on the map to finally be recognized by
Emergency Management, who had previously ignored us, and became an
integral part of their operations.” And this recognition occurred in
1992, well over a decade after the passing of the CB fad, and some seven
years after the introduction of the cellular telephone.  HF CB Radio
Service operations at 27 MHz remain an unquestionable, unwavering and
absolutely essential component of emergency wireless communications, and
likewise, of Homeland Security.

IN CLOSING

It is unconscionable that the Commission would seriously consider a mode
of
communications delivery that specifically and deliberately causes mass
pollution of the
electromagnetic spectrum environment. Good engineering practice has
always sought to
minimize unwanted emissions. And the FCC is the statutory guardian of
spectral purity (47 USC
§§151, 152, et seq.). These BPL proceedings completely ignore the
unproductive and
obstructive radiation filth that fouls and renders the surrounding air,
to all or to any degree,
unusable. This is not a matter of studies, measurements, and testing.
The concept of radiating
HF-band signals from unshielded wires goes right down to the most basic
roots of RF physics
that is basic and universal knowledge among radio engineers and
technicians. Promoters of BPL
are attempting to sell America a perilously faulty bill of goods, by
utilizing an old technology long abandoned as functionally obsolete due
to its inherent flaws. And in this process, they are leveraging a
perceived technological illiteracy on the part of the Honorable
Commissioners, that such a scheme would produce the desired results
without also producing the unintended consequences. Additionally, among
radio engineers and other persons allegedly learned in RF propagation;
any who claim that BPL will not cause spectral noise and interference
are either incompetent, woefully ignorant, or are bending truth to fit a
political agenda. The consequences for all are very real, and they will
be in practice, severe. Certain parties will surely be held accountable
for the debacle, and I dare speculate that the technological, legal, and
political fallout won’t be pretty.
The 27 MHz CB radio band, along with all other authorized services in
the HF spectrum; our national Amateur Radio Service, International
Broadcasting, Maritime, Aviation, Part 90 “utility”, and most certainly
NTIA military and Homeland Security/FEMA HF DX services; must be
protected completely from any interference capable of raising the
ambient noise floor.

Most, if not all, HF communications involve long-distance transmission
or weak-signal modes,
or both. Any compromise in the ambient noise floor level is clearly
unacceptable. Any such
compromise will result in catastrophic failure of all HF DX/weak-signal
communications by
absorbing all of these weak signals within such elevated noise level.
Some BPL proponents
claim that they will eliminate radio interference by notch filtering out
affected HF spectrum
subbands. This solution is patently ridiculous since the entire HF
spectrum is already allocated
to various licensed radio services. Once all portions of occupied
spectrum in the HF, as well as
the MF and VHF bands being considered have been “notched out”, the
remaining segments
would allow for only a very, very narrowband—rather than
broadband—distribution service,
indeed! Hence, the Broadband-over-Power-Lines concept, with the current
generation of unshielded electrical service cables and wiring, is
clearly unacceptable, and interfering radiation cannot possibly be
otherwise mitigated given the inviolate laws of physics. Therefore, the
instant proceeding must be dismissed, with prejudice.

Sources

Comments, ET Docket 03-104, American Radio Relay League, Newington, CT.
7 July 2003.  Standard Trucking and Transportation Statistics, ATA
Economics & Statistical Analysis Department. American Trucking
Associations, Inc. Feb./Mar. 1999, pp. 1,7.  Goldenber, J., Libai, B.,
and Muller, E. (Apr. 2002). “Riding the Saddle: How Cross-Market
Communications Can Create a Major Slump in Sales.” Journal of Marketing,
Vol. 66, pp. 1-16.  Ting, Carol, et al. The Rise and Fall of Citizens’
Band Radio in the US, National Science Foundation Research project
preliminary report. Michigan State University, East Lansing, MI.  2003.

Actions Taken or Needed to Curb Widespread Abuse of the Citizens Band
Radio Service, Report to Congress. US General Accounting Office,
Washington, DC. 1975.  US Freight Transportation Forecast…to 2006,
Standard & Poor’s DRI. 1997.
Young, Walt. Letter to author. 19 Aug. 2003.

Additional information referenced from:
Dealerscope Merchandising.
Cobra Electronic.
Federal Communications Commission.
Midland Radio Corp.

SUBMITTED ELECTRONICALLY

This day, 3 May 2004
Alan Dixon, N3HOE
2721 Maderia Circle
Melbourne, Florida
32935-5594

Contributing Editor, Popular Communications Magazine

Senior Wireless Telecommunications Engineer, Retired

Former Republican Candidate for Appointment to the FCC (1996)

General Radiotelephone Operator Certificate PG-4-19631

GMDSS / Radar - Operator and Maintainer DB-GB-005305

General Mobile Radio Service Licensee/System Operator WPUC720

Amateur Radio Service Extra-Class Licensee N3HOE

Member – American Radio Relay League (ARRL)

Member – Salvation Army Team Emergency Radio Network (SATERN)

Affiliate Member – Radio Emergency Affiliated Communications Teams
(REACT)

Ex-Officio – Baltimore County, Maryland Fire Communications Committee

Ex-Officio – Baltimore County, Maryland 911 Task Force

Former Member – TIA / EIA Standards Committee TR45-AHAG

Awarded – Congressional Order of Merit, 2003

Member – Alpha Chi Honor Society

CORES FRN: 0003-3350-56

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6516183228

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