Ofcom Stakeholder Meeting: PLT August 3 2010, Riverside House, London.
The attendees congregated in the lobby of Riverside House prior to the meeting and some useful exchanges too place between the pro-radio delegates.
The meeting started at 1100 BST sharp and the following organisations were represented:-
Ofcom (Enforcement, Licensing, R&D, Field Ops, COO)
BIS
PA consulting
Comtrend
EC (DG Enterprise)
DS2
Civil Aviation Authority
BBC Domestic
BBC World Service
BT
EMCIA
UKQRM
RAOTA (Veteran radio amateurs)
RSGB
Session 1. (PA presentation & questions), 1100 BST.
1. COO opens meeting and leaves.
2. Julian Lake (PA, Project Manager of report) presents report & summarises. "In conclusion, firstly, all the HF services require notching." 11:26 BST
3. PA failed to model flats / high-rise & other very high density areas which will be the worst polluters of all PLT installations.
4. BIS appeared to not understand the difference between PLA and BPL. BIS confirmed that there is renewed interest in BPL commercially.
5. PA were unable to answer technical questions, failed to respond appropriately to criticism of inconsistencies and were clearly influenced by the corporate claims of new mitigation technology which is unproven by field testing.
6. The Civil Aviation Authority appear to be deeply troubled by the PA report and want PA's assumptions tested & verified; PA's consideration of 1% as negligible is not an acceptable order of magnitude for CAA and they intend to take action, but uncertain what action.
7. The EMCIA provided proof that the new Power Control specification is not a power reduction scheme but a power increase scheme, whereby the level of interference generated by the current Comtrend devices falls in the centre of the power range and could in fact be increased by a further 15db above this level: i.e. Power Control = Comtrend +/- 15dB (not forgetting that Comtrend is already 36db above EN55022).
8. BBC called into question the PA assumptions on worst-case, suggesting that this more closely represents average radio equipment scenarios.
9. UKQRM / John Pink challenged PA that Smart Notching is invalid by way of the devices will be looking at an "antenna" which will not necessarily be sensitive on all appropriate frequencies and that the devices will be looking at a noise floor which is already polluted with PLT thereby invalidating the noise floor.
10. Jonathon Stott (ex-BBC) expands on UKQRM / JP assertion by stating that originally all Smart-Notching PLT was intended to have a synchronised silent period so that the noise floor could be determined and without this the devices could not make any meaningful measurements and that this feature has disappeared from the specification.
11. PA's assumptions regarding mitigation have been chronically undermined by input from EMCIA, RSGB, UKQRM, CAA, BBC and thus any conclusions weighted by proposed mitigation techniques are equally undermined.
12. PA stand by their report insomuch that action is urgently required. EMCIA, RSGB, UKQRM, CAA, BBC, RAOTA agree this position.
Session 2 (Ofcom Questions) (1204 BST).
PA was not present.
1. Ofcom accept the report's technical conclusions but state that the report does not affect their regulatory position on enforcement.
2. Ofcom accept there is a gap in the legislation regarding enforcement of this technology but also confirm that if they had such powers they would only use them under safety of life circumstances and that Ofcom is not obligated to cure all interference complaints.
3. Ofcom's faith in its own statistics is challenged and JP together with the EMCIA illustrate that Ofcom's reporting system is flawed.
4. DG Enterprise, who is not a Stakeholder, reiterates Ofcom's position and was clearly there to keep Ofcom in line and to support them.
5. CAA are so concerned that they have tasked their lawyers to find legislation to deal with PLT polluters. The CAA has also tasked two airlines to test for the presence of interference which could prove significant should PLT deployment continue using the current unmitigated technology.
6. Comtrend challenged by UKQRM to ship product with BC / IARU / Aeronautical already notched. Comtrend side-step.
7. Comtrend spouted typical corporate "we are your friend" line and challenged the meeting delegates to provide evidence of one of its products causing interference to radio. They got what they wished for (G7CNF) but Ofcom intervened to prevent the truth from being told to all meeting delegates.
8. Ofcom reject that the Essential Requirements have been breached despite repeating the mantra "evidence based regulator" and having evidence of the breaches. (Ofcom are re-interpreting the position according to their needs). Or as Richard Marshall put it, "Ofcom have changed the rules…"
9. EMCIA challenge Ofcom's reporting system as dysfunctional. Also challenge Ofcom that operating "evidence based" will not work for cumulative interference as the realisation of the problem comes after it's too late to remedy and laws of physics should be used for this decision process.
10. BBC World Service is worried for its listeners and has received complaints. Ofcom and BBC at odds with who is responsible for shortwave interference.
