Comments on BPL or PLC.

24 February 2004


* INTRODUCTION *

My name is John Matz.  I have been an amateur radio operator 
for 40 years, currently Amateur Extra Class, current callsign 
KB9II.  I have a BSEE and MSEE from Northwestern University.  
I am a Professional Engineer.  I worked as an antenna designer 
for 4 years, for Motorola Research for 4 years, in Motorola 
Microwave for 9 years, in Motorola Cellular Infrastucture for 
10 years.  I am now an independent consultant.  


* BPL COMMENTS *

Part 15 limits:

If it's an unintentional radiator, are there any limits below 
30 MHz at all? Does it have to meet the intentional radiator 
limits?

If it's an intentional radiator, 30 uV/m at 30 meters below 
30 MHz.  But in what bandwidth?  Above 1000 MHz the resolution 
bandwidth is given as 1 MHz minimum.  But I saw nothing below 
1000 MHz.  

*** You must specify a bandwidth !!!***  

Below 30 MHz, Part 15's limit is 30 uV/m @ 30 meters. This 
corresponds to about -80 dBm/sq meter at 30  meters.  At 
14 MHz and lower, atmospherics are conservatively estimated 
at 34 dB above the thermal noise floor. The 30m and 20m bands 
can be much quieter.  The atmospheric noise using a dipole 
receive antenna in a 10 kHz BW shortwave receiver is about 
-100 dBm equivalent at the antenna (NEP).  That's about 2 uV 
on 50 ohms.  Using Part 15 limits measured in a 1 MHz BW, the 
interference is about -65 dBm in 1 MHz, or about -85 dBm in 
10 kHz, or about 15 dB above typical atmospherics.  If the 
Part 15 limit is measured in 10 KHz BW, noise could be 35 dB 
above atmospherics.  Part 15's 30 uV/m, if measured in 1 KHz 
BW, would give interference at 45 dB over atmospherics.    

*** You must specify a bandwidth !!!***  

At 30 MHz, the atmospherics will drop down to maybe 4 dB above 
thermal noise, so any BPL noise at Part 15 limits becomes 
really obvious at 40 dB to 70 dB over receiver noise.  

Just a comment, light dimmers, brushes, etc.  will cause 
60/120 Hz modulation of the noise.  This will be very annoying 
on AM detection for SW BC, etc. 

I think people have forgotten that 30 dB is a factor of 1000 
and 60 dB is a factor of 1,000,000. That's big !!


* MORE BPL COMMENTS *

The BPL NPRM Appendix C:

The test procedure calls out a loop antenna below 30 MHz, 
oriented in a vertical plane and rotated about a vertical axis.  
If I read this right, this does NOT measure any horizontally 
polarized radiation. 

Above 30 MHz, a biconical dipole, parallel to the wire, rotated 
V and H, is specified.  If I read this right, it does not measure 
any Er.  This Er doesn't propagate, but it's still noise to be 
picked up locally.  


* ADAPTIVE INTERFERENCE COMPENSATION *

one of the proposed interference mitigators is adaptive 
compensation.  I am not sure what this will be, but in OFDM 
as proposed, it may simply mean not using data carriers on 
a frequency where the unit can detect activity.  In a DSSS 
system, notches may be used to remove offending frequencies.  
The adequacy of these countermeasures is questionable if many 
frequencies are in use in the system and/or a transmission 
has not occurred near the frequency in question (SWL's).  
Notches of 30 dB help but don't eliminate a 60 dB degradation.


* GENERAL* 

Part 15, as it stands today, is very inadequate to control 
noise and interference.  The measurement bandwidth is not 
specified.  The standards are the same at 1.705 MHz and at 
30 MHz.  That's a factor of 17 in frequency, a factor of 300 
smaller in dipole antenna capture area (25 dB), and most 
importantly, a reduction in atmospheric band noise of 50 dB 
from a simple vertical or dipole.  Also antennas at 30 MHz 
are often 10 dB gain, that is, they have 10 times the capture 
area of a dipole.  That means that 30 uV/m in 1 MHz varies 
from -55 dBm in 10 kHz with an atmospheric noise of -80 dBm 
(25 dB degradation) to -70 dBm from a small beam pointed at the 
power wires with an atmospheric noise level of -130 dBm (60 dB 
degradation).  

The only reason Part 15 sort of works is that spurious emissions 
used to be unmodulated and narrowband carriers.  That's why 
bandwidth was not even specified.  A problem would only even 
exist for a small extent in frequency.  In the case of BPL, heavy 
data modulation fills the whole spectrum with interferers.  It 
will be bad over whole bands at a time.

People have asked will it have long distance effects since these 
bands support ionospheric propogation.  Well at 10 MHz, free space 
path loss in 300 kilometers is about 80 dB more than the loss in 
the first 30 meters, so the contribution of a short section of 
power line should be very small.  Having 1000 of the noisy sections 
would raise the noise 30 dB, still OK.


* MODULATION *

Apparently the modulation techniques are proprietary, so we must 
assume something.  If the data rate per user is 1 MBPS and we 
could have ten downloads simultaneously, the aggregate data rate 
is 10 MBPS.  Since the system is relatively robust, we will assume 
a simple modulation scheme, so the modem output occupies 10 MHz 
of spectrum in the range 2 to 80 MHz.  Let's also assume that two 
systems are in service so 20 MHz is used, with guard bands, this 
is 30 MHz. This is about half the available band.  It is possible 
to "move around" a bit, especially with an OFDM-based modem, but 
since almost all the spectrum is allocated, the modem is going to 
step on someone.  Of course, propagation being variable, there may 
be preferred frequencies to avoid at certain times of day and season 
and solar cycle.  If the system is lightly loaded so there is some 
"elbow room", it might be acceptable.  



* RECOMMENDATIONS *

If the BPL network just makes Part 15, the interference potential 
is huge.  

The keys to operating this system without interference is frequency 
agility of the transmitters/injectors and the willingness of the FCC 
to call this a Part 15 service that must not interfere with licensed 
stations and operations.  They must adjust or shut down.  The 
problem is that what will be considered more important, one 
interference problem or 500 paying Internet connections dropped.  
In the past, the FCC seemed to do what had to be done.  Now ... 
I don't know.  The FCC may just buckle under public pressure.

Anyway, Part 15 needs to be re-vamped, tightened, and clarified 
to be really usable to control interference in the 21st century.  
The measurement bandwidth should be specified.  Similarly, the 
spurious specification for transmitters of -13 dBm should have 
a measurement bandwidth associated with it.  Also, -13 dBm is 
really not tight enough at VHF and UHF frequencies to control 
interference.  Japanese and European goals are often 20 dB tighter 
to be accepted by regulatory agencies.  

Also the measurement techniques of NPRM Appendix C need to be 
revised.  Not all cases are even measured, such as horizontal 
polarization below 30 MHz. 

John Matz KB9II
24 Feb 2004