BPL Technical Rules

1. BPL Technical Rules INTERNET Brett Kilbourne Associate Counsel United Power Line Council May 23, 2007

2. OUTLINE • Background on Technical Rules • FCC Rules • Definition of Access/In-House BPL • Emission limits • Interference mitigation • Measurement guidelines • Equipment Certification • Status Update • Conclusions

3. FCC Technical Rules (Background) • Part 15 and Carrier Current Systems • BPL is a Part 15 unlicensed operation, which is subject to a general condition that: “no harmful interference is caused and that interference must be accepted” from any other licensed or unlicensed operation. • Harmful interference is defined as: “Any emission, radiation or induction that endangers the functioning of a radio navigation service or of other safety services or seriously degrades, obstructs or repeatedly interrupts a radiocommunications service.” • BPL is a type of carrier current system, defined as: “A system, or part of a system, that transmits radio frequency energy by conduction over the electric power lines. A carrier current system can be designed such that the signals are received by conduction directly from connection to the electric power lines (unintentional radiator) or the signals are received over- the-air due to radiation of the radio frequency signals from the electric power lines (intentional radiator).”

4. FCC Technical Rules (Background) • Part 5 and Experimental Authority • BPL equipment may be operated on a test/temporary basis. • FCC adopts BPL Rules to promote BPL and to provide “consistent and repeatable” measurement procedures. • Report and Order (FCC 04-245), released Oct. 2004; • R&O affirmed (FCC 06-165), August 2006.

5. FCC Technical Rules (Overview) • R&O addresses five main areas: • Definition of Access/In-House BPL • Emission limits • Interference mitigation • Measurement guidelines • Equipment Certification

6. Definition of Access/In-Home BPL Systems • Access BPL System: “A carrier current system installed and operated on an electric utility service as an unintentional radiator that sends radio frequency energy on frequencies between 1.705 MHz and 80 MHz over medium voltage lines or over low voltage lines to provide broadband communications and is located on the supply side of the utility service’s points of interconnection with customer premises. Access BPL does not include power line carrier systems as defined in Section 15.3(t) of this part or In-House BPL as defined in Section 15.3(gg) of this part.” • In-House BPL System: “A carrier current system, operating as an unintentional radiator, that sends radio frequency energy by conduction over electric power lines that are not owned, operated or controlled by an electric service provider. The electric power lines may be aerial (overhead), underground, or inside the walls, floors or ceilings of user premises. In-House BPL devices may establish closed networks within a user’s premises or provide connections to Access BPL networks, or both.”

7. Regulation Distance V/m dBV/m Carrier Current Systems 1-30 MHz 3 3000 69.5 10 270 48.5 30 30 29.5 3 300 49.5 Class A Digital Devices 30-88 MHz 10 90 39 30 30 29.5 3 100 40 Class B Digital Devices 30-88 MHz 10 30 29.5 30 10 20 FCC BPL Emission Limits • FCC affirms radiated emission limits, and clarifies that Class A limits apply to MV Access BPL

8. FCC Interference Mitigation Rules • Capabilities • Access BPL systems shall incorporate adaptive interference mitigation techniques to remotely reduce power and adjust operating frequencies, in order to avoid site‑specific, local use of the same spectrum by licensed services. These techniques may include adaptive or “notch” filtering, or complete avoidance of frequencies, or bands of frequencies, locally used by licensed radio operations.

9. FCC Interference Mitigation Rules • Capabilities (cont’d) • Access BPL systems shall comply with applicable radiated emission limits upon power‑up following a fault condition, or during a start‑up operation after a shut‑off procedure, by the use of a non‑volatile memory, or some other method, to immediately restore previous settings with programmed notches and excluded bands, to avoid time delay caused by the need for manual re‑programming during which protected services may be vulnerable. • Access BPL systems shall incorporate a remote-controllable shut‑down feature to deactivate, from a central location, any unit found to cause harmful interference, if other interference mitigation techniques do not resolve the interference problem.

10. FCC Interference Mitigation Rules • Notching Standards • For frequencies below 30 MHz, when a notch filter is used to avoid interference to a specific frequency band, the Access BPL system shall be capable of attenuating emissions within that band to a level at least 20 dB below the applicable Part15 limits. • For frequencies above 30 MHz, when a notch filter is used to avoid interference to a specific frequency band, the Access BPL system shall be capable of attenuating emissions within that band to a level at least 10 dB below the applicable Part 15 limits. • At locations where an Access BPL operator attenuates radiated emissions from its operations in accordance with the above required capabilities, we will not require that operator to take further actions to resolve complaints of harmful interference to mobile operations.

11. FCC Interference Mitigation Procedures • FCC creates informal resolution process. • BPL operators must post system/contact information to BPL database within 30 days prior to operation • Licensees must contact the BPL operator first before complaining to the FCC. • FCC imposes good faith duty by BPL operators and licensees to identify and resolve interference. • Time frame to respond to complaints: • In general: according to a “mutually acceptable schedule” • For public safety radio interference complaints: 24 hours to respond -- and if no response in that time -- shut down. • FCC acts as backstop and will entertain complaints if interference is not resolved.

12. Special Protections • Bands of Exclusion • Spectral restrictions protect aeronautical frequencies • Zones of Exclusion • Geographic restrictions protect coast stations and few VLBA stations • Consultation Areas • Advance 30 day notice protects aeronautical, astronomy and radar receiving stations • Also, BPL operators must consult with local public safety licensees 30 days prior to operation. • Special protections are narrowly tailored by NTIA.

13. Measurement Guidelines • In-house BPL • In situ testing around home and along power lines connected to the home. • Conducted and radiated emissions. • Lab tests for computer peripherals. • Access BPL Systems • Overhead installations: in situ testing along MV and LV lines. • Underground installations: in situ testing at radials around the transformer. • Extrapolation factor • 40 db/decade < 30 MHz • 20 db/decade > 30 MHz

14. Equipment Certification • All Access BPL equipment that is manufactured, imported, marketed or installed after July 7, 2006 must be certified by the FCC to comply w/rules. • Existing systems grandfathered for one year to supplement/replace equipment in the existing footprint.

15. Technical Rules Status Update • FCC Affirms BPL Rules (8/06) • ARRL appeals to DC Circuit (10/06) • Raises procedural and substantive issues with regard to record evidence, interference protection and measurement rules. • Intervenors: UTC, NAB, MSTV, Ambient, Current, Duke and Manassas (11/06) • FCC Dismisses Manassas Complaint (12/06) • FCC has granted 14 applications for equipment certification from 5 vendors (1/07). • Rep. Ross (D-AR) reintroduced bill (HR-462) for a further FCC study of BPL in the House of Representatives (1/07).

16. Final Words on FCC Rules • FCC rules are working • NTIA endorses rules during testimony 3/22 before House Telecom/IT subcommittee. • Testified that NTIA Study showed that the interference potential from BPL “could be very well-understood and easily mitigated”; Study incorporated into the FCC rules to provide technical and regulatory certainty, leading to wide-scale deployments of BPL. • BPL rules are tougher than for any other Part 15 operations • New equipment certification rules improve mitigation • 35 systems operating in the U.S. today for broadband and utility services • Large scale deployments underway in Dallas, Houston, Charlotte and Cincinnati.

17. For more information, please contact UPLC: www.uplc.org Brett Kilbourne Director of Regulatory Affairs/Associate Counsel United Power Line Council 1901 Pennsylvania Avenue, NW – Fifth Floor Washington, DC 20006 USA 1.202.833.6807 brett.kilbourne@utc.org Any Questions?