1. Examining the pitfalls of Power Line Telecommunication (PLT) Hans van de Groenendaal South African Radio League

2. Back Ground? Power Line Telecommunication has met with lots of resistance in most parts of the world. Power Line Telecommunication has met with lots of resistance in most parts of the world. There is very little proof (if any) of successful large scale deployment of PLT There is very little proof (if any) of successful large scale deployment of PLT Will the draft ICASA PLT regulations fly? Will the draft ICASA PLT regulations fly?

3. What are the PLT risks? Currently there are no performance or interference standards- hence the interim draft regulations Currently there are no performance or interference standards- hence the interim draft regulations Power reticulation is of varying standards which is often a major contributory factor to the HF radio interference problem. Power reticulation is of varying standards which is often a major contributory factor to the HF radio interference problem. USA Installations considered successful are now being challenged in the courts USA Installations considered successful are now being challenged in the courts

4. Have Interference problems been disproved? A recent test carried out by the SABS under the auspices of ICASA at a site in Rooiwal showed significant interference on a wide range of HF frequencies A recent test carried out by the SABS under the auspices of ICASA at a site in Rooiwal showed significant interference on a wide range of HF frequencies The intention of the tests was to give ICASA an indication of the risk to the radio frequency spectrum, mainly in the short wave spectrum, below 30MHz The intention of the tests was to give ICASA an indication of the risk to the radio frequency spectrum, mainly in the short wave spectrum, below 30MHz

5. Rooiwal

6. Rooiwal

7. SARL INTEFERENCE TEST Saturday 22 July 2006 at approx 17:00 Saturday 22 July 2006 at approx 17:00 The radio installed in the vehicle was a ICOM 726 connected to a Hustler antenna with 80 and 40 M elements resonated at 3,640 and 7,060 MHz. The radio installed in the vehicle was a ICOM 726 connected to a Hustler antenna with 80 and 40 M elements resonated at 3,640 and 7,060 MHz. The initial observation 3,640 MHz The initial observation 3,640 MHz As the vehicle entered the Township the interference increased to 9 +20 dB As the vehicle entered the Township the interference increased to 9 +20 dB Observations were made on the corner of 4th and 8th Streets and the S meter still registered 9+20 dB. Observations were made on the corner of 4th and 8th Streets and the S meter still registered 9+20 dB.

8. Cape Town Test On the request of ICASA a test was carried out with Motorola Equipment installed on an underground cable reticulation On the request of ICASA a test was carried out with Motorola Equipment installed on an underground cable reticulation Results were encouraging. The full report is pending Results were encouraging. The full report is pending Another test using the same equipment is planned on overhead reticulation Another test using the same equipment is planned on overhead reticulation

9. Why is HF so important in the African Context? The HF spectrum provides long range communication The HF spectrum provides long range communication In many African Countries broadcast stations have to use HF frequencies to cover the country In many African Countries broadcast stations have to use HF frequencies to cover the country Airlines use HF to keep in touch with their aircraft flying over Africa Airlines use HF to keep in touch with their aircraft flying over Africa Medical emergencies ( Red Cross) Medical emergencies ( Red Cross) Peace keeping operations Peace keeping operations Maritime emergencies Maritime emergencies Military applications Military applications Mining operations Mining operations

10. NEXT STEP FOR PLT ICASA has published a set of draft regulations ICASA has published a set of draft regulations But do the regulations go far enough to protect the HF frequency spectrum? But do the regulations go far enough to protect the HF frequency spectrum? Not so according to various submissions Not so according to various submissions

11. Main Points from SARL SUBMISSION The FCC did not include the exclusion of amateur HF frequency bands in their regulations but paid a heavy price with large number of interference complaints and on going court action. The FCC did not include the exclusion of amateur HF frequency bands in their regulations but paid a heavy price with large number of interference complaints and on going court action. The latest is that the courts ruled in favour of the ARRL on two counts The latest is that the courts ruled in favour of the ARRL on two counts

12. The Court agreed with the ARRL that the FCC had failed to comply with the APA by not fully disclosing for public comment the staff studies on which it relied. The Court agreed with the ARRL that the FCC had failed to comply with the APA by not fully disclosing for public comment the staff studies on which it relied. The Court also agreed with the ARRL that the Commission erred in not providing a reasoned justification for its choice of an extrapolation factor of 40 dB per decade for Access BPL systems and in offering "no reasoned explanation for its dismissal of empirical data that was submitted at its invitation." The Court also agreed with the ARRL that the Commission erred in not providing a reasoned justification for its choice of an extrapolation factor of 40 dB per decade for Access BPL systems and in offering "no reasoned explanation for its dismissal of empirical data that was submitted at its invitation."

13. The FCC did not include the exclusion of amateur HF frequency bands in their regulations but paid a heavy price with large number of interference complaints and on going court action. The FCC did not include the exclusion of amateur HF frequency bands in their regulations but paid a heavy price with large number of interference complaints and on going court action. It is interesting to note that in the USA, as a practical matter, BPL manufacturers have had to avoid the ham bands and are notching the amateur radio frequencies as a matter of cause. The SARL therefore request again that all amateur bands be included in the table of Frequency Band Exclusion. It is interesting to note that in the USA, as a practical matter, BPL manufacturers have had to avoid the ham bands and are notching the amateur radio frequencies as a matter of cause. The SARL therefore request again that all amateur bands be included in the table of Frequency Band Exclusion.

14. In draft rule 6.5 a notch depth of 20 dB is recommended. This has proven to be inadequate. In draft rule 6.5 a notch depth of 20 dB is recommended. This has proven to be inadequate. The state of the art of the technology is that notch depth is at 35 dB as a minimum. The state of the art of the technology is that notch depth is at 35 dB as a minimum. Having a 35 dB requirement would not be a major burden on the industry but would avoid most major interference problems if coupled with Amateur band exclusions. Having a 35 dB requirement would not be a major burden on the industry but would avoid most major interference problems if coupled with Amateur band exclusions.

15. Complaint – Resolution processes Complaint – Resolution processes The "mutually agreeable schedule” is not a workable practice and could lead to extended periods to reach agreement. If the industry has the mechanism to respond to public-safety complaints within 24 hours, there is no reason not to apply that standard to all interference complaints. The "mutually agreeable schedule” is not a workable practice and could lead to extended periods to reach agreement. If the industry has the mechanism to respond to public-safety complaints within 24 hours, there is no reason not to apply that standard to all interference complaints.

16. Is it worth taking the risk? While the PLC interference debate is ongoing other broadband systems are forgoing ahead and are being deployed While the PLC interference debate is ongoing other broadband systems are forgoing ahead and are being deployed HSPA HSPA WiMAX WiMAX WIFI WIFI VSAT VSAT Is there a future for PLT? Is there a future for PLT? As a last mile solution – doubtful As a last mile solution – doubtful As an internal broadband distribution medium – there seems to be some opportunities As an internal broadband distribution medium – there seems to be some opportunities

17. Conclusion The South African Radio League supports technology innovation The South African Radio League supports technology innovation It is the whole essence of the existence of Amateur Radio It is the whole essence of the existence of Amateur Radio No innovation must be to the detriment of the Radio Spectrum No innovation must be to the detriment of the Radio Spectrum We have only one such national resource We have only one such national resource

18. Amateur Radio Communication Technology in Action