Attached are my comments to: Notice No. SMSE-005-05 – Consultation Paper on Broadband over Power Line Communications System Created in Microsoft WORD 2000 XP home edition I am a licensed amateur radio operator – VE7BWC, and am very concerned about the proposal to allow the BPL system, as anyone near power lines will experience harmful interference to incoming signals. There will be interference over a huge area and it will not only affect Amateurs. An example: ships at sea use HF (High Frequency) for any distance communications, as VHF is only useful for vessels in close proximity to one another. Long distance distress signals intended to be received at a shore-based station will be totally unreadable for any station near a power line. This will be true for any number of civil and commercial services. The amateur radio service has proven itself to be extremely useful in recent emergencies, being almost the only working communication after the disasters have struck. Almost all receiving stations worldwide are near power lines. In most disaster scenarios the amateur operators are using battery power so the signals coming out are not strong but with good conditions can be read over thousands of miles away. These signals would be unreadable unless and until there is major refinement of the proposed system. With today’s state-of-the-art technology in many disciplines it seems preposterous that such a system as BPL should be allowed. As it stands now it should be scrapped or put on hold, as it will be a massive assault on a huge area of the radio spectrum. If in the future a way is found to refine the system it might be considered again at that time. Robert Allison, 1179 Cloverley St, North Vancouver, BC, V7L 1N7 [email protected] NSARC NEWSLETTER – 20 NOVEMBER 2005 – NUMBER 548 THE NSARC CALENDAR 22 November: 2 metre net: 1900 hours, 147.26 MHz, Net Control: Erik VE7ZQ 23 November: RAC Forum on the air, 1900 hours on 147.18 MHz. (details below) 24 November: HF Group meeting (see details below) 29 November: 2 metre net: 1900 hours, 147.26 MHz. Net Control: Bob VE7RPX 1 December: General meeting. There has been a program change. See details below. 6 December: 2 metre net: 1900 hours, 147.26 MHz. Net Control: Bill VA7BIL 8 December: Christmas Dinner. See details below. THIS WEEK'S HIGHLIGHTS: 1. The Dec. 1 Program: Dirk VE7DRK's presentation on "The Gerry Brewer Building" has been put off till February. The amateur radio hobby, as well as this Club, attracts people from all walks of life. Occasionally the Club persuades those members with unique or different vocations to share some information about their work. On December 1, Leif VA7CAE will talk about his vocation. To use a ham-originated expression, "come and have an eyeball with Leif" and find out what he does for a living. 2. The Christmas Dinner will be held on December eighth at the North Shore Winter Club. Tickets for members and their guests are $30 each, available for the last time at the December first meeting, or you can contact Alan Jones VA7ALJ for tickets. 3. The HF Group meets this Thursday. Nick VA7NRM will unravel the mysteries of Smith Charts as well as discuss tuners. 4. The RAC Forum On The Air, Wednesday Nov. 23: Radio Amateurs of Canada Director Ed Frazer VE7EF will conduct RAC Forum On The Air, hosted by the Oceanside Radio Communications Association (ORCA) of Parksville/Qualicum on Repeater VE7RBB 147.180 (+) The VE7RBB repeater covers the Vancouver area. Lower Mainland hams are invited to check in and participate. Check-in at 1900 hours for the ORCA Net. The RAC Forum follows at 1930 hours and runs until 2000 hours. Topics will include, - RAC and amateur radio update. - Report on meeting with the Canadian Amateur Radio Advisory Board (CARAB) in Ottawa on Nov. 3. (CARAB meets twice annually with RAC and Industry Canada). - No-code HF operation, and the new rules. - - Update on Broadband Over Power Line and response to IC Gazette Notice SMSE-005-05 (Responses to IC are due Nov. 28). 5. November 28 is the deadline for Industry Canada to receive your views on the implementation of Broadband over Power lines. Please do your share to advise Industry Canada that you are concerned about interference to HF signals. Sample Response to Gazette SMSE-005-05, Broadband over Power Line To download a sample response: - Go to the Radio Amateurs of Canada Home Page at www.rac.ca . - Right Click on "Sample Response to Gazette SMSE-005-05, Broadband over Power Line" - Select "Save Target as..." - Select a Directory on your computer in which to download the MS- Word file "2005_11_BPLResponse". Read the suggestions in the first page, and then delete it from the document being sent to Industry Canada, as well as removing all of the RED comments. To view or download the Industry Canada Gazette Notice SMSE-005- 05, go to: http://strategis.ic.gc.ca/epic/internet/insmt- gst.nsf/en/sf08432e.html Then click on the title: "Consultation Paper on Broadband over Power Line (BPL) Communication Systems" to download the Paper. 6. Today's link: Your are hearing a lot about RAC and Amateur Radio Clubs working on preserving our radio spectrum. This sounds like a lot of work and the need for a lot of resources. But if you really want to see what our American friends are doing about this very same subject, take a look at http://www.arrl.org/news/stories/2005/11/15/2/?nc=1 North Shore Amateur Radio Club http://www.nsarc.ca Feedback? [email protected] 147 East 14th Street North Vancouver, BC V7L 2N4 Frank Andersen 8805 East Saanich Road Sidney BC Canada V8L 1H3 250-655-1301 November 10, 2005 Director General, Spectrum Engineering Branch Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8 Subject: Response to Canada Gazette Notice SMSE-005-05 dated July 19, 2005 Consultation Paper on Broadband over Power Line (BPL) Communications Systems Dear Sir: GENERAL I wish to comment on the document referred to above. Industry Canada's decisions on the matter of BPL can have a severe impact on the ability of licensed and authorized radio users to receive and communicate on MF, HF and VHF spectrum, and in particular, on the future of the Amateur Radio Service. I have been a licensed amateur radio operator for 20 years. I am involved in radio communications for personal enjoyment, as well as for the benefit of our community, and in particular to provide communications during local, national and international emergencies where other communications means have failed. Having reviewed your Paper and other available literature on the subject, I believe that the introduction of BPL with the proposed emission limits, will create harmful interference to authorized and legitimate uses of the radio spectrum. In its current state of development, wide-area BPL could have a devastating effect on radio users in the range 2 – 80 MHz and beyond, and deprive them of a legitimate use of this spectrum. RESPONSE The following sections follow the numbering in Canada Gazette notice SMSE-005-05: 2 3. General Description of BPL Systems No Comment 6.0 Discussion and Proposals The Department also seeks comment on any other specific issue or concern relating to the Department’s role in the deployment and regulation of BPL systems in general. The amateur radio service is a significant resource to the local, national and international community, particularly in times of emergency. During major disasters such as the Katrina storm, the Asian Tsunami, and Okanagan fires, amateur radio via MF, HF and VHF networks was often the only communication available during and days after each disaster. BPL systems, in their present form, have the capability of interfering with or totally preventing radio operations. The Department has a substantial obligation to preserve the ability of radio systems to continue operation. 6.1 Equipment Standard and Approval Process We agree that a technical standard is required for the equipment and the operating system. However, because the power-line is not designed for efficient transfer of Broad-Band signals, it is essential that the installed system be made compliant with a system standard that does not create harmful interference to other licensed or authorized users of the spectrum. 6.2 Prospective Technical Requirements 6.2 (a) Emission Limits Access BPL systems operating below 30 MHz will be subject to following limits: Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 1.705-30.0 30 30 Access BPL systems operating above 30 MHz will be subject to the following limits: Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 30-80 90 10 The Department seeks comment on the above limits and their suitability for Access BPL systems in Canada. Please provide technical rationale. The proposed emission limits for BPL systems will create harmful interference to typical MF/HF/VHF signals that are being received by radio operators adjacent to BPL-carrying power lines. Ideally, the emission limits should be 40 dB less, or 0.3 uV/meter at 30 meters. Most Amateur Radio stations are located within 30 m of a LV or MV power line. A dipole 3 antenna located near a BPL power line (often less than 30 m) will intercept an interfering BPL signal that is substantially greater than the typical weak-signal from a distant station. An emission level of 30 uv/m would block all reception except for the very strong signals, which are not typical.