Conformity Magazine - December 2007 - (Page 14) The NATO report further notes that “as these lines were not designed for such broadband transmissions, they will cause unintentional RF emissions which may adversely affect the established radio noise floor directly, or by cumulative propagation from many such sources. The existing HF background noise possibly may be increased via ground wave and/or sky wave propagation.” The report continues that the “increase of the existing HF noise floor by widespread use of PLT and/or xDSL will bring up problems for Military Radio Users as well as for HF Communication Intelligence (COMINT) in all NATO countries.” “Currently, there are no commonly accepted regulatory emission limits from PLT,” the report notes. Since NATO, by itself, has no regulatory authority over the emission limits, the report recommends “that NATO seek the implementation of this goal by working together with the national and international regulatory authorities.” Continued Concerns from Amateur Radio The interference concerns are so great that the ARRL, the national association for amateur radio operators, filed a federal appeals court brief earlier this year outlining its case and requesting oral arguments in its petition for review of the FCC’s BPL rules. The ARRL petitioned the U.S. Court of Appeals for the DC Circuit to review the FCC’s October 2004 Report and Order, and its 2006 Memorandum Opinion and Order. In its brief, the ARRL contended that the FCC’s actions in adopting rules to govern unlicensed BPL systems fundamentally alter the longstanding rights of radio spectrum licensees, including amateur radio operators. Figure 1: BPL equipment mounted on an electrical pole in Cottonwood, AZ. (Photo courtesy of Robert Shipton.) “For the first time ever, the FCC has permitted new unlicensed devices to operate in spectrum bands already occupied by licensees, even if the unlicensed operations cause harmful interference to the licensees,” the ARRL said in stating its case. “The orders under review reverse nearly seven decades of consistent statutory interpretation and upset the settled expectations of licensees without so much as acknowledging the reversal, let alone justifying it.” The ARRL argued that the FCC’s approach to adopting rules to govern BPL does not agree with Section 301 of the Communications Act, which requires that operators of devices that emit radio frequency energy first obtain an FCC license. According to the ARRL brief, “the FCC has consistently read Section 301 to apply to unintentional radiators, such as BPL devices, and has expressly embodied that interpretation in its rules.” In July, the FCC replied to the court that its authority to permit BPL as an unlicensed communications service comes from Section 302 of the Communications Act of 1934, which allows it to regulate the interference potential of RF devices, as opposed to Section 301, which is the basis of Part 15 rules that generally regulated unlicensed devices. The FCC also said its rules protect mobile and fixed stations against harmful BPL interference and that there is conflicting evidence on the science involved in determining the rate at which a signal weakens with distance from a radiator. Oral arguments were presented before a three judge panel in Washington, D.C. in late October. The ARRL argument 14 Conformity DeCember 2007 http://www.maruwa-g.com/e/index.html http://www.maruwa-g.com/e/index.html
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