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Broadband Over Power Line and Amateur Radio Ed Hare, W1RFI ARRL Laboratory Manager 225 Main St Newington,CT 06111 [email protected] 860-594-0318

EMCS Chicago 2005 Ham

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Broadband Over Power Line

and Amateur Radio

Ed Hare, W1RFI

ARRL Laboratory Manager

225 Main St

Newington,CT [email protected]

860-594-0318

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Rules of W1RFI¶s Presentations

It is okay to get up and leave!

Everybody has to laugh at my jokes! I am the only one allowed to tell any jokes!

Ask questions any time.

Falling asleep. . .

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In the US, Regulated by FCC Part 15

On October 14, 2004 the FCC made significant

changes to the rules governing BPL

Although this was seen by some to mean thatthe FCC now allowed BPL, it had been legal all

along under existing FCC rules

The new rules place new restrictions on BPL

that are intended to control its interferencepotential

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The Thrill of Victory or the

Agony of Defeat?

When the FCC started out the BPL

Notice of Inquiry, Commissioner

Abernathy said that she believed that

most of the rules restricting BPL could

be changed.

The new rules did not remove a single

restriction, but added new ones

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What Was Kept? Absolute-maximum limits defined in Part 15

Carrier-current must meet limits for intentional

emitters Part 15 also is clear that unlicensed devices such as

BPL must not cause any harmful interference andthey must accept any interference caused to them

Manufacturer responsible for FCC authorizationand maximum limits

Operator responsible for harmful interference

Both components to the rules are necessary forPart 15 to work 

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Intentional Emitter Radiated

Emissions Limits - HF

Sec 15.209 1.705-30.0 MHz -- 30 QV/m at 30 meters

These limits should protect users of the

spectrum against interference, yes?

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No! If the absolute emissions limits were set to offer

unconditional protection to all radio services, the

permitted levels would be unworkably low

Amateur Radio Service, by design, uses sensitiveequipment and weak signals

The ³legal limit´ will result in a strong signal to

nearby amateur HF installations On 3.5 MHz, a half-wave dipole placed in a 30 QV/m

field will receive a ±86.4 dBW signal (338 QV across50 ohms)

To amateurs, this is S9+16 dB ± clearly harmfulinterference to typical amateur communications!

The absolute limits are not enough to preventinterference to nearby receivers

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Levels: International work in progress:

FCC levels much higher than other nations or proposals

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The Bottom Line

The legal limits result in strong signals to

nearby receivers

Nearby receivers that will receive interferenceif they are trying to receive signals on the same

spectrum as analog signals

In residential neighborhoods, the risk is

typically to Amateur Radio, Citizens Band and

international shortwave broadcast

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Fields Near Large Radiators ± 14 MHz

30 meter/3 meter ratio 16 dB

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Harmful Interference

Defined as the repeated disruption of radio

communications or any disruption of certainemergency communications services

Merely hearing a signal is NOT harmfulinterference

30 QV/m at 30 m works to a degree for discretefrequency signals

If from broadband device, however, willinterfere with entire band(s)!

30 QV/m works to a degree for isolated pointsources

If from PLC, level will occur for entire lengthof line in areas where access PLC is deployed!

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Harmful Interference ± the BPL Perspective

"It is Progress Energy·s position and interpretation of theFCC's rules with regard to 'harmful interference' that any

interference that may still exist is not 'harmful' as that

term is defined by the FCC's rules," Len Anthony, PEC's

attorney for regulatory affairs, told James Burtle, chief of 

the FCC's Experimental License Branch. "This level of interference does not seriously degrade ham radio

operation or transmissions or cause repeated

interruptions."

The FCC defines as "harmful" any interference that

"seriously degrades, obstructs or repeatedly interrupts a

radiocommunication service operating in accordance with

the Radio Regulations."

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How do I know it is BPL? It is possible to misidentify BPL

Each BPL system has a unique sound

Some are spread spectrum ± broadband noise

Some are OFDM, broadband noise or multiple

carrier Onset vs spectrum is generally over about 100

kHz

If the noise has a strong 60- or 120-Hz

component, it is probably ³regular´ power-linenoise

If heard every 10-50 kHz, as a buzz or asbirdies, it is probably a computer, TV set or

switch-mode power supply

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S pectrum Chart: This shows the present

use of spectrum:

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S pectrum with BPL from 2-80 MHz:

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BPL Could Interfere With: Emergency

management

National Guard

US Coast Guard

U.S. Military

Fire Departments Law Enforcement

CAP

FAA

FEMA

NASA

Voice of America

TV stations Amateur and CB

radio

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Other organizations that share

ARRL¶s concerns: Federal Emergency Management Agency

National short-wave listener associations

Short-wave broadcasters

Aeronautical

NTIA has done field measurements in

Potomac, MD and Emmaus, PA They released a report on their findings

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Examples from ARRL Filings

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Residential Noise + 10 dB

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Residential Noise Levels

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Part 15 Noise Levels

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EMC Issues

Proper test methods

Extrapolation vs height

Extrapolation vs distance Compatibility with radio services

Standards and good design practicemust take over where regulations

leave off 

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Test methods Standards for test methods are under development

Measure at 1 meter height Below 30 MHz, extrapolate at 40 dB/decade ³slant-

range´

Above 30 MHz, extrapolate at 20 dB/decade

Above 30 MHz, add 5 dB for height Measure E field with magnetic loop

Other than measuring an electric field with amagnetic loop in the near field, what is wrong with

this test method? Actually, ARRL modeling showed good correlation

between E and H peaks

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Test Methods Measure in situ for 3 typical overhead and

underground wiring sites (6 sites)

Measure for CPE, injector, coupler, repeater

That¶s a lot of testing!

At 10 distances along line for 4 different devices of 5 MHz bandwidth between 5 and 50 MHz, that is:10 measurement points * 3 systems * 2 (overheadand underground) * 4 types of devices * 9frequency segments = 2160 scans

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Test Methods (continued)

G

ood practice requires that the 6 strongest peaksbe recorded and logged

And in situ, ambients will kill you, and each

³peak´ must be demodulated and a determination

made that it is a BPL signal, not an ambient

This is 2160 * 6 = 12,960 demodulations

G

oing from 10 meters horizontal to 3 metershorizontal doesn¶t buy much because the slant

range changes little

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Extrapolation vs Distance FCC rules speify that measurements made at other than

compliance distance may be extrapolated to compliancedistance

Rules specify 40 dB/distance decade below 30 MHz and 20dB/decade above 30 MHz

This is a wide range of opinion on whether 40 dB/decade isappropriate for line emitters

ARRL has provided FCC with antenna modeling andtheoretical analysis showing why a power line is a line source

Models show 40 dB/decade along ground

Models show 20 dB/decade for measurement made at 1meter to true maximum at height

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Example NEC Analysis

(Spatial Distribution of E Field)

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Ingress Initial tests show that BPL is susceptible to ingress

from nearby transmitters

Amateur radio may use EIRPs of 20 kW or more

Field strength at power lines may be 100 V/m (160dBuV/m), more typically 10 to 25 V/m

Tests show as little as 10 watts can take it down

More testing is needed, but industry reluctant to doso

Utilities reluctant, too, which is much lessunderstandable, although two are discussingimmunity testing with ARRL volunteers

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What is needed? It is critical that all unlicensed emitters that operate

anywhere near the FCC limits avoid locally used spectrum

To avoid degrading a licensed service, typically, a 1 dBdegradation is used

This would require that noise be 6 dB lower than the desiredsignal

If the median values of man-made noise are used for N, thenthe level of BPL emissions at the receive-system antenna onspectrum that must be protected would range from 0

dBuV/m on lower HF to ±10 dBuV/m on upper HF

This would generally protect mobile operation, and mostfixed operation

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What is needed?

The values of man-made noise in ITU P378-2are median values

Lower levels are common in communicationschannels used by services with frequencyagility

At some stations in the Amateur Radio Service,field strength at the antenna of ±20 dBuV/m inquiet areas of a given band would be found

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How can this be achieved?

Notching is a technique whereby BPL use of certain portions of spectrum is turned off 

Notching is typically 20 to 30 dB notch depth

This is not enough to achieve the levels in the previous

slide if starting at the FCC limits. To achieve compatibility with nearby radio services,

operating at a lower emissions level and puttingadditional guard bands around spectrum that is being

 protected is necessary

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How can this be achieved?

One way that the a lower operating level couldeasily be achieved with minimum changes to therules would be to use a smaller distanceextrapolation factor.

A formula that used about 30 dB/decade at 1 MHz,decreasing to 20 dB/decade above 30 MHz wouldmatch modeled and measured results

A simplification of this to 23 dB/decade would be areasonable approach

This would allow the typically achieved 25-30 dBnotching to be adequate to protect HF and low-VHF

mobile stations

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How can compatibility be

achieved? Some fixed stations require additional notch

depth

One BPL manufacturer has shown that it is practical to do this with hardware filters

These filters also help with ingress

They can be used in all of a product line, or  be applied on a case by case basis whereneed, if they are available

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The goal is NOT to try to design systems

or regulations that have no potential for

interference. That would not be

reasonable or practical. An attainable goal

is to design systems that have a low-

enough incidence of interference that it is

practical to resolve that interference on a

case-by-case basis. This requires the

additional goals of having that practical

solution available and to use those

solutions where necessary.

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Is Amateur Radio Doomed?

No! In a speech last year, FCC Commissioner 

Abernathy stated that she envisioned that mostrules that were restricting BPL could be removed.

In a letter issued several months later, she clarifiedthat protection against harmful interference was a³bedrock´ position.

In October, 2004, the FCC came out with an

announcement of new rules that removed NOrestrictions, but proposed to add requirements thatapply to no other unintentional emitter 

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The work being done by amateur 

radio IS having an effect, and wecan continue to emphasize to all

involved that power lines are not

the right place to put high-speed

digital signals using the same

spectrum as local radio receivers

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Video

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What is ARRL doing? Here¶s the short list«

Working with local amateurs in BPL areas Filing supporting interference complaints

Funding measurements in BPL areas where appropriate

Federal Court of Appeals if necessary

Maintaining contacts and presence in standards area Ed Hare is chair of IEEE EMCS SDCom BPL study

 project

Making other affected users aware of BPL interferenceissues and explaining how to file complaints

Articles in QST and on ARRL web pages

Petition for Reconsideration

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Cooperation ARRL has a track record of working cooperatively with

industry Over years, it has worked with the cable industry;

VDSL; Home Phone Networking Alliance

It has worked with HomePlug on their Version 1

standard and expects to work with them on theupcoming AV standard

BPL industry generally believes cooperation meansdoing what they can, then when it falls short, start

³blaming the victim´ The door is still wide open for sincere cooperation

In one BPL test site, ³cooperation´ did not eveninclude the BPL manufacturer taking a 10-minute ride

to observe interference

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Recon Petition

Procedural and technical flaws in the rulemaking FCC concluded that interference potential low

650 pages of unreleased correspondence and testdata

This material showed unresolved interference anda considerable interference potential

FCC testing supported ARRL¶s position

Redaction

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EMC Standards Work 

IEEE Standards Association 4 major standards under development

Hardware and safety (P1675) (PES)

EMC (P1775) (PES and EMCS)

Protocols and interoperability (P1902) (ComSoc)

By decision, EMC does not address compatibility with radioservices

IEEE EMC Society Standards Development CommitteeEMC Study Project

ANSI-accredited C63 BPL working group

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What Can You Do to Help?

Membership

File comments with FCC

Right place at the right time

SDCom BPL study project

Measurements

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Q&A

a.k.a. Stump the Speaker

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MORE INFORMATION

Ed Hare, W1RFI

ARRL Laboratory Manager

225 Main St

Newington,CT [email protected]

860-594-0318

http://www.arrl.org/bpl [email protected]

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