QRM Problems - pt. 2

Detailed Technical Study showing the Non-Compliance of PLT HomePlug products with the EMC Directive [link] >>

Who REALLY Sanctions PLT?  (update November 2009) more >>

RSGB_goes_to_law_over_PLT_radio_interference (September 2009) >>

Spectrum Defence Fund announced The RSGB announced in the January edition of RadCom, that the Society has established a Spectrum Defence Fund to challenge Ofcom over its interpretation of the various Acts and Directives that cover PLA/PLT and the threat they pose. This may take the form of a Judicial Review, but we will be advised by our lawyers on the direction to take. The cost of a Judicial Review is likely to be in excess of £75,000 and we are not guaranteed success. But now is the time to stand up and be counted and make it known that we, as a community of radio amateurs and short wave listeners alike are not prepared to accept any level of interference from non-compliant devices. We are looking to our administration, Ofcom, to protect our interests, which is their statutory duty. This is a long term project and all monies donated will be ring-fenced for those actions alone. To donate to the Spectrum Defence Fund please make cheques payable to The Spectrum Defence Fund and send them to Spectrum Defence, RSGB, 3 Abbey Court, Priory Business Park, Bedford MK44 3WH. Alternative methods of payment such as PayPal etc will be announced in due course. The RSGB is appreciative of the efforts and support from Society members, the UKQRM group and its membership, among many others. You can now donate on-line to the Spectrum Defence Fund at http://www.rsgb.org/defencefund

I Have Donated

I have just sent my donation to the RSGB Spectrum Defence Fund  http://www.rsgb.org/defencefund

As far as I see it this is absolutely vital, and far more important than the next accessory, antenna or radio, so I have made a reasonable donation immediately and will be prepared to continue to make donations if / when necessary.

I have been trying to bring this matter to the attention of fellow radio enthusiasts, SWL's, CB users and amateurs for many months as I feel that too many people simply do not realise or understand the disastrous consequences of these illegitimate devices.

Fifteen months ago I wrote a very strong letter the the RSGB expressing my concern that nothing *appeared* to being done about interference from PLT adapters. I was reassured that there was work being done behind the scenes, as it were.

Now, all of a sudden, the RSGB has sprung into more public action, which is to be credited.

We must ALL - radio enthusiasts and licensed amateurs alike - support the RSGB in the defence of the precious radio spectrum, not only by joining the RSGB as members, but also contributing to The Fund.

Many of us must have each spent many hundreds, if not several thousands of pounds on equipment, so £20 / £50 even £100 is not a lot to ask by comparison.

We can blame Ofcom fairly and squarely for this dire mess. Is it due to their bungling incompetence? I expect that they have their fair share of bungling incompetents, but I suspect that their failure to protect (what is / should be ITU) coordinated spectrum is far more sinister than mere British bungling - PLT is far worse than a farce.

This is, at best, wilful neglect by Ofcom, and even disregarding all their other regulatory failures, this matter alone surely proves that Ofcom is a completely, utterly and totally unfit body.

The poor Ofcom field engineers and front line staff do, in the main, seem to remain diligent and helpfully cooperative, despite the cynical spin and misinformation from their Ofcom masters and the misdirection from the lying labour government spin merchants.

I will keep a close eye on the RSGB's Spectrum Defence measures and make future donations the The Fund as the issue progresses.

Mike.  M0MTJ

Universal Declaration of Human Rights 1948-1998 Article 19 says: Everyone has the right to freedom of opinion and expression; this right includes freedom to hold opinions without interference and to seek, receive and impart information and ideas through any media and regardless of frontiers. In this respect the deliberate or otherwise jamming of world band radio (shortwave) and amateur transmissions is in direct conflict with this act! ..

Big Business - aided by sinister regulators - is attempting to CRUSH traditional citizens' rights to communicate using the high frequency, short wave, radio bands for communication. http://www.frequencycast.co.uk/cast32.html

NOW IS THE TIME FOR ALL RADIO USERS TO STAND UP ND BE COUNTED - NOT ONLY FOR THEMSELVES, BUT ALSO FOR THEIR FELLOW USERS: "In Germany, they came first for the Communists, And I didn’t speak up because I wasn’t a Communist; And then they came for the trade unionists, And I didn’t speak up because I wasn’t a trade unionist; And then they came for the Jews, And I didn’t speak up because I wasn’t a Jew; And then . . . they came for me . . . And by that time there was no one left to speak up" Martin Niemöller

Are we going to stand by and allow the whole sale jamming of the short wave radio spectrum?

British Telecom with its BT Vision package and many independent electrical and computer stores/outlets are supplying power line adaptors to as many homes as they can!

What's wrong with that you might ask?

Well there is one element of this package that is causing the death of short wave radio!

Shortwave radio is the medium used by most International Broadcasters to transmit their programming to the World. Commonly referred to as World Band Radio, it has amazing properties that allow world wide communications and it has been in use since Marconi made his first historic transmissions.

Shortwave broadcasts are found in the 2Mhz to 30Mhz band of the radio spectrum (just above the Medium waveband) and include many thousands of users: Military, Shipping, Long Range Aircraft communication, Space, Amateur, safety of lives and World Broadcasters.

Many Millions of people listen to short wave radio every day, some relying on it for their very existence.

Modern short wave equipment is very sophisticated and can even be computer controlled.

Shortwave radios cost from a few pounds to many thousands of pounds (GBP £) There is a huge world market in shortwave equipment!


We believe it is of paramount importance that its uninterrupted use is maintained and protected.

Yet despite all this various companies have chosen to ignore this and obliterate this well used and loved radio band. Not only that but it would seem that the EU and our own government has turned a blind eye!


The UKQRM is a group for people to come together and fight against this stupid poorly designed and legally questionable technology!

The problem is caused by the Power Line Adaptors (Powerline Ethernet)

These are used to set up a home network by passing signals over the mains wires of the house! carrying video and data. To do this they use the almost all of the shortwave spectrum 24 hours of every day! even while no data is being passed.

The result is that the mains wires being unscreened act just like antennas and broadcast the video/data far and wide outside of the house concerned!

This has little to do with Internet access or being connected! you don't need power line ethernet to use the Internet or even BT Vision! UKQRM is not trying to stop people being connected to the Internet, why would we? we all use it every day.

Have a look at this You Tube video to see and hear what its like!


Many thousands of people use and listen to short wave radio every single day here in the UK and around the globe, its uniqueness and ability to allow far flung stations around the world to be tuned in from the comfort of your arm chair has fascinated and delighted generations.

This is all under threat now!


Universal Powerline Association (UPA) as used by the BT Comtrend adaptors and Home Plug Power Alliance (HPA) less intrusive but still a problem! Our main focus is the UPA type but we are also very concerned about the HPA and any type of Power Line Communication.


Join us at UKQRM if you are suffering from this interference or feel you could contribute to our very active group.



 

To the best of my knowledge the UK laws and regulations already hold the answer to these problems! we have to ask why they have not been enforced. To the best of my knowledge here are extracts from two UK acts.

(Noted is the fact that Ofcom will respond albeit slowly to complaints of spectrum abuse, however their powers of enforcement seem limited BT however have been (to date) very helpful and have removed the offending adaptors when a complaint is made)

The Wireless Telegraphy Act 2006 and The Communications Act 2003 both say this and define harmful interference as:

For the purposes of this Act interference is harmful if—

(a) it creates dangers, or risks of danger, in relation to the functioning of any service provided by means of wireless
telegraphy for the purposes of navigation or otherwise for safety purposes;
or

(b) it degrades, obstructs or repeatedly interrupts anything which is being broadcast or otherwise transmitted

(i) by means of wireless telegraphy; and

(ii) in accordance with a licence under this Act, regulations under the proviso to section 1(1) of this Act or a grant of recognised spectrum access under Chapter 2 of Part 2 of the Communications Act 2003 or otherwise lawfully."

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What Is The RSGB Doing?
The RSGB's EMC Committee has been battling against Radio Frequency pollution for many years. The introduction of ADSL broadband, many years ago now, presented a potential radio interference problem from wideband digital communications. The RSGB helped the formation of the British Standard MPT1570 with the cooperation of BT and The then Radiocommunications Agency (forrunner to Ofcom).

More recently the RSGB has had to turn its attention to the thread of RF pollution from PLT and BPL. PLT is a technology that power companies, for example, could use to deliver broadband connections over the electricity grid using the HF radio spectrum from 2 to 30 MHz - thereby making the use of HF impossible for general radio communication.

The work to protect the radio spectrum from this type of abuse has been supported by the RSGB and has contributed to the continuing Standards work at the BSI and is aimed at keeping 'unintentional emitters' under control. This has so far meant that there has been little general PLT roll-out so far.

The next big battle is against the 'in-house' home-plug broadband by powerline adapters. If the general adoption of these home-plug devices is not controlled then the problem of radio frequency pollution will be disastrous.

The RSGB's EMC committee is involved with the International Electrotechnical Commission. The big business PLT lobby is trying to remove any existing standards that aim to protect the HF radio spectrum from interference: The RSGB and other similarly interested parties are attempting to prevent their efforts.

The efforts of the RSGB take a commitment of time by volunteers and financial resources.

The RSGB continue to press the UK regulator Ofcom on the matter and have also requested that BPL home-plug adapters should be removed from sale.

However national regulators such as Ofcom and the German regulator BnetzA are declining to take any action against these spectrum polluting devices - probably because they do not want to get involved in potentially expensive and drawn out legal action.

This is, of course, a case of sheer neglegance on the part of the UK regulator Ofcom and demonstrates that they are not willing to undertake their Statutory Duty.

In the mean time it must be the duty of EVERY RADIO AMATEUR and ENTHUSIAST to report every single case radio interference caused by BPL / Home Plug spectrum abuse to Ofcom: Use Ofcom's London call centre to make each complaint and ask for a reference number so that the complaint can be tracked.

The battle continues.........

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What Is The REAL STORY Behind PLT and the interference it causes?  (update November 2009)

As with so much of what is allowed to happen in Britain today, the hidden influence comes from the unaccountable monstrosity that is Brussels and the E.U.

In 2008 I wrote to my MEP's expressing my concerns over the obvious ELECTROMAGNETIC INCOMPATIBILITY of PLT adapters and inevitable radio interference that PLT (BPL etc) causes. The MEP's disingenuous replies stated that the E.U. Commission had no influence over the matter and that the matter was (effectively) not their concern as PLT was dealt with by the UK authorities - i.e. Ofcom.

The truth (as ever with the unaccountable E.U.) turns out to be entirely the opposite.

ONCE AGAIN the British Public are tripped over by E.U. bureaucracy while our MP's, representatives and regulators have their HANDS TIED by meddling E.U. bureaucrats. Britain, it would appear, is impotent and has no control over the issue.

Here is a written question to the E.U. Commission by Graham Watson. The answer confirms that the E.U. has authority over the general adoption of PLT technology in Britain and across Europe and - worse than that - the Commission expects that the technology will be more generally adopted for new and different uses - using the Green Argument as the further excuse:-

(From the Yahoo UKQRM Forum) Parliamentary questions 29 July 2009 E-3813/09

WRITTEN QUESTION by Graham Watson (ALDE) to the Commission

Subject: Power line telecommunications

High-speed Internet communication is a cornerstone of the Lisbon Strategy and its development is rightly seen as essential in aiding the recovery of Europe's economy. There has been considerable success in liberalising the many stages involved in providing broadband access, speeding up progress and making the technology widely available to homes and offices around Europe. However, progress has been slower in the `last mile' of broadband delivery.

Power Line Telecommunications (PLT) is a technology with the potential to promote greater competition in this area. However, there is much disagreement amongst regulators and industry experts about its impact on electromagnetic compatibility (EMC) and aeronautical, maritime and broadcast signals. What is the Commission's view on PLT interference? Does the Commission believe that PLT technology conforms with existing agreements on EMC?

There have been attempts to create a European standard for the EMC of Telecommunications Networks but confusion still appears to reign, preventing progress and advancement in broadband delivery. What steps is the Commission taking to create a common standard that protects EMC whilst also supporting affordable access to high-speed Internet?

16 September 2009 E-3813/2009

Answer given by Mr Verheugen on behalf of the Commission:

Power line communication technology (PLT) contributes to the development of the Information Society and the Knowledge-based Economy. However, for more then 10 years PLT has been the subject of a controversial discussion in the EU. This is due to the
fact that this technology uses installed electrical cables that are not designed for high speed data. This can cause radio interference that users of shortwave frequencies consider unacceptable. Those interference are unstable and hardly predictable since all electrical networks are different from each other. It is important to understand that it is the networks which radiate radio waves, and not
the PLT devices themselves.

PLT are subject to Directive 2004/108/EC (Electro Magnetic Compatibility (EMC))(1) relating to electromagnetic compatibility. Already in 2001 the Commission mandated the European Standardisation Organisations to develop PLT harmonised standards under
this directive. As of today, appropriate standards, whether at device level or network level, are not yet really available. The only one proposed is considered by many to be inadequate and gives rise to incompatible interpretations. Standardisation is carried out by independent institutions — European or global organisations. However, in 2008 substantial progress was made by standardisation
bodies and the Commission is now confident that adequate standards will emerge within the next two years and will integrate the appropriate mitigation techniques recently developed by PLT manufacturers.

In 2005 the Commission issued a Recommendation (2005/292/EC)(2) to Member States to ensure transparent, proportionate and non-discriminatory conditions for the deployment of powerline communications systems, and removal of any inappropriate regulatory barriers. Moreover, the recommendation recommends Member States to be vigilant and report on potential difficulties with this technology. Since then, according to the information the Commission possesses, there have been relatively few problems. There are now approximately 10 million PLT devices in use throughout the EU. Most problems seem to occur in the United Kingdom (UK). Out of 206 established interference cases in the EU in 2007/08, 184 were based on radio amateur complaints, 140 by UK radio amateurs. Radio amateurs often try to capture radio signals from the other side of the world for which they need a perfect radio wave
silence. To the knowledge of the Commission, the UK authorities are aware of the issue and are working on solutions, where necessary by prohibiting the device owner to continue using the installation in question. In the past three years, only one PLT model was banned from sales by a Member State. The Commission is not aware of problems in the aeronautical or maritime area. By and large, PLT systems are already conformant to the existing EMC framework and agreements, and the Commission expects
that in 2010/2011 the new mitigation techniques incorporated in new EMC standards will eliminate completely the possibility of borderline cases.

For the time being PLT has a rather restricted market for in-house/ in-office high speed connection. A new application of PLT is emerging through the development of Smart Grids associated with renewable sources of energy and the EU's long‑term objectives for Carbon Dioxide reduction. The future grids must `host' efficiently all new power producers (individual solar installations, wind mills, etc.) and therefore need sophisticated and automated communication capabilities. The cheapest option for the communication functions of those grids is to reuse their cables and install PLT. Those networks are still at the designer stage.

The Commission will continue to closely monitor the use of PLT in the EU.

(1) Directive 2004/108/EC of Parliament and of the Council of 15 December 2004 on the approximation of the laws of the Member States relating to electromagnetic compatibility and repealing Directive 89/336/EEC. Text with EEA relevance, OJ L 390, 31.12.2004.

(2) Commission Recommendation of 6 April 2005 on broadband electronic communications through powerlines (Text with EEA relevance), OJ L 93, 12.4.2005.

The fact that the E.U. appears to be a driving force behind PLT / BPL (etc) technology might ensure that our own British law makers and the regulator, Ofcom, may have little or no influence over this disruptive technology.

Has this revealed an Ofcom / E.U. conspiracy? This certainly seems to have lifted the curtain on a hidden agenda.

(September 2009)

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What's Happening In The United States Of America?


ARRL

It Seems To Us: We Win In Court!

By David Sumner, K1ZZ

July 01, 2008

Last year, in the wake of Federal Communications Commission decisions that did not adequately protect licensed radiocommunication services from interference from Broadband Over Power Line (BPL) systems, the ARRL went to court to challenge the FCC. 

On Friday, April 25 the United States Court of Appeals for the District of Columbia Circuit confirmed what the ARRL has been saying for years about how the FCC was handling the BPL interference issue: FCC prejudice tainted the rule making process.

In fact, the FCC's mishandling of the issue was so egregious that the Court took an unusual step: it did not defer to the Commission's presumed expertise on a highly technical issue.

The Court of Appeals found that the FCC violated the Administrative Procedure Act by not disclosing in full the staff studies on which the Commission relied. Writing for the three-judge panel that heard American Radio Relay League, Incorporated v. FCC and USA, the ARRL's petition for review of the FCC's Orders in ET Docket No. 04-37, Circuit Judge Judith W. Rogers said: "It would appear to be a fairly obvious proposition that studies upon which an agency relies in promulgating a rule must be made available during the rule making in order to afford interested persons meaningful notice and an opportunity for comment…there is no APA precedent allowing an agency to 'cherry-pick' a study on which it has chosen to rely in part….The League has met its burden to demonstrate prejudice by showing that it 'ha[s] something useful to say' regarding the unredacted studies…that may allow it to 'mount a credible challenge' if given the opportunity to comment….Under the circumstances, the Commission can point to no authority allowing it to rely on the studies in a rulemaking but hide from the public parts of the studies that may contain contrary evidence, inconvenient qualifications, or relevant explanations of the methodology employed….no precedent sanctions such a 'hide and seek' application of the APA's notice and comment requirements." 

In a concurring opinion, Circuit Judge David S. Tatel wrote: "[I]n this very case the Commission redacted individual lines [emphasis in original] from certain pages on which it otherwise relied….there is little doubt that the Commission deliberately attempted to 'exclude[ ] from the record evidence adverse to its position'…."

The Court also found that the Commission failed to justify its decision to apply an "extrapolation factor that was designed to accommodate technologies different in scale, signal power, and frequencies used" to Access BPL and that it "summarily dismissed…empirical data that was submitted at its invitation." The Court found that the FCC's Reconsideration Order "…provides neither assurance that the Commission considered the relevant factors nor a discernable path to which the court may defer."

While the Court did not agree with us on every point, it found that the FCC's decision-making process was seriously flawed. The Court concluded, "On remand, the Commission shall afford a reasonable opportunity for public comment on the unredacted studies on which it relied in promulgating the rule, make the studies part of the rulemaking record, and provide a reasoned explanation of its choice of an extrapolation factor for Access BPL systems." In explaining its choice of an extrapolation factor the Commission must either "provide a reasoned justification for retaining an extrapolation factor of 40 dB per decade for Access BPL systems sufficient to indicate that it has grappled with the 2005 studies [three published studies suggesting that an extrapolation factor of 20 dB per decade may be more appropriate -- Ed.], or adopt another factor and provide a reasoned explanation for it."

You can read the entire decision in American Radio Relay League, Incorporated v. FCC and USA at http://pacer.cadc.uscourts.gov/common/opinions/200804/06-1343-1112979.pdf

The Court's decision is a tremendous victory for radio amateurs and other licensed users of the radio spectrum -- indeed, for anyone who cares about the integrity of the federal administrative process. Yet, the remand does not guarantee that the FCC will correct its errors. We face another round of technical arguments. No doubt the FCC's technical staff, many of whom want to do the right thing, will remain under heavy pressure to ignore the laws of physics and give preference to wishful thinking once again. When the FCC reopens the BPL proceeding as the Court has ordered, we must leave no room for these technical issues to be settled on anything other than technical grounds. There's more work to do!

While all this was going on, the ARRL technical staff -- principally Ed Hare, W1RFI -- was working quietly with the BPL industry, persuading them that it was in their best interest to fix the interference problem. To their credit, the leading companies have taken the problem seriously and have gone beyond what the FCC rules require. But it took great effort, including our frontal assault on the flawed FCC proceedings, to get their attention.

The responsible BPL companies have shown they can do what's necessary to avoid interfering with Amateur Radio. FCC rules requiring all BPL companies to take these steps will protect them from irresponsible competitors.

BPL received another blow on May 1 when it was announced that the largest BPL deployment to date, in Dallas, would not be used to offer Internet service but would be used only to monitor the power distribution network. The Associated Press report began, "Goodbye, broadband over power lines. We hardly knew you." Thus the marketplace has added its verdict to that of the Court of Appeals.
This good news notwithstanding, the ARRL will not rest until the FCC rules give licensed radiocommunication services the protection they are entitled to under international agreements and federal law.

Even as we celebrate these dual verdicts, we cannot afford to become complacent. Our access to the radio spectrum is much too important to allow us that luxury.

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What's Been Happening In Australia?


On Thursday 11 January 2007, Australian regulator ACMA undertook another round of measurements at Conrad VK7HCK's QTH. Equipment was specially flown in from Melbourne, with Conrad, Phil VK2DKN, Harvey VK7HK, Greg VK7YAD and myself in attendance.

Measurements were taken using a flat-response loop antenna and also using Conrad's quad and vertical antennas so a comparison could be made between the calibrated professional antenna and tuned amateur antennas.

There was definite correlation between what Conrad was reporting using the "S" signal strength scale and what was measured using the test equipment on the same antenna.

ACMA took notch profile measurements which showed up to a 20dB notch depth however this still resulted in about an S3-4 signal level being experienced by Conrad within a notch.

As some background, Conrad put in a complaint of unacceptable levels of interference from BPL emissions in November 2005 and then again in September 2006, and these have been the subject of an ongoing investigation by ACMA.

ACMA staff undertook initial measurements at Mt Nelson in November 2005, June and July 2006. ACMA even detected emissions at the Quoin Ridge ITU monitoring station which is 20km away back in November 2005, however that is no longer the case, possibly due to the utilisation of wireless technology for the BPL back-haul network.

Following Conrad's complaint of September 2006, ACMA compiled their measurement results into a report which was released at the end of November 2006 and reported signal levels ranging from 34.1 to 64dBuV/m across the HF amateur bands.

This ACMA report substantiates the claims made by Conrad that the Aurora Energy BPL system is causing interference and greatly reducing his ability to operate licensed amateur radio equipment.

It was acknowledged during the measurement day, that Aurora has, through notching and wireless backhaul, reduced the level of emissions over the period of the trial.

Conrad has requested further reductions in emission levels including the widening of notching in various bands and notching of the 10m band.

We await with interest the release of measurement results from this round of testing.

Justin VK7TW    [  http://www.southgatearc.org/news/january2007/bpl_battle_200106.htm  ]

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Hi Mike,
 
Thought you might be interested to know that we've just featured the HomePlug / Powerline / Shortwave story our tech podcast.

You can listen at:  http://www.frequencycast.co.uk/cast32.html