[10m] BPL Comment Period Now Open

Wed, 17 Mar 2004 23:06:41 -0500

Ray, Thank you for your information.  I have filed a comment.  I don't
know the number or how to review it or I would show the URL.  Following
is a copy of my filing.  I hope it is useful and effective.  

Thanks again, 

Buck
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Broadband Over Power Lines (BPL) poses a threat to a number of
communications mediums including but not limited to Amateur Radio,
Military Affiliate Radio Services (MARS), Amateur Radio Emergency
Service (ARES), US Military communications, Ship to Shore communications
and Shortwave Broadcast communications.  BPL generates a level of
interference on High Frequency radio bands (HF) that reduces the
usability of any communication used on these frequencies totally
unusable. 

A number of devices have been authorized to operate on some of the same
frequencies with limited power and cause little to no interference with
normal communications on or near the operating frequency of the device.
This is due to the fact that these devices use a very narrow frequency
spectrum or channel and the range is limited to 100 feet or less from
the device.  Even with the same limitations, BPL will cause a serious
interference problem.  First of all its bandwidth is larger than any
single amateur radio or broadcast band spectrum and usually, if not
always, it covers multiple bands all at the single time. 
There is no escaping the interference by changing frequency.  Secondly,
most other devices are in use only for a short period of time.  BPL will
be on 24/7 as long as any customer is on the internet.  Additionally,
the transmission area of common part 15 devices is restricted to a
specific geographic location such as in one home.  Because BPL transmits
through open-wire, specifically power lines, it radiates a signal all
along the way of its transmission.  This interference is difficult at
best to escape in an automobile and impossible in a base location.  An
automobile may travel for many miles and not escape the area of effect.
This will ever get more and more difficult to do as BPL is distributed
to more and more rural areas.  Power lines mostly run along highways and
roads so an automobile would have to go off-road or many miles away from
civilization in order to operate outside the area affected by BPL
radiation.

Radio propagation will ultimately cause BPL to be heard in foreign
countries as well.  It is a well known fact that amateur radio operators
(Hams) have been known to communicate to foreign countries in Europe,
Africa and Asia and elsewhere with very low levels of power even under
one watt.  As the signal travels in the atmosphere, BPL will also follow
radio propagation and may cause interference with people in foreign
countries trying to listen to their favorite shortwave broadcast or even
to their ham radios.  

Emergency HF communications is sure to be interrupted as well.  While
one might suggest that BPL be disabled in a disaster area, doing so will
not begin to solve the problem.  I operated emergency communications
with the Emergency Management Agency (EMA) from Charleston, South
Carolina a few days after Hurricane Hugo crippled a number of South
Carolina counties.  HF communications were responsible for requesting or
directing desperately needed supplies, rescue workers were directed to
the homes of many elderly and sick to see if they were ok.  At least one
elderly man was rescued from his home because a ham over 1000 miles away
was able to communicate to me with my weak signal.  BPL in his area
would have made that communication impossible.  

Amateur Radio Operators (Hams) are not the only ones affected or opposed
to BPL radiation.  Shortwave Broadcasters are concerned as their signals
will also be covered by the BPL radiation.  Even the Federal Emergency
Management Agency (FEMA) which is part of Homeland Security has opposed
the approval of BPL because of its radiation.  They believe that BPL
radiation is a threat to national security.  

I have been reading discussions about BPL and viewed the Amateur Radio
Relay League's video on it's test in the BPL test areas.  It is
available at the ARRL website
(http://www.arrl.org/news/stories/2003/08/08/2/?nc=1).  I have also
experienced BPL interference first hand.  On at least one day, my radio
was rendered useless for a minimum of 4 hours either by a local BPL test
or a propagation reception where the signal strength was 10 db over 9 on
my S-meter.  I was forced to turn off the radio as it was useless with
that level of interference.  

I am not opposed to any electric company as the loss of electricity
would radically alter my lifestyle and quality of life.  I am not
opposed to broadband Internet technology. I use it daily and, while not
to the same level, my lifestyle would be radically altered at the loss
of it as well.  I am opposed to BPL technology as it has been tested and
demonstrated.  If power companies would like to offer broadband internet
services, they really should seek to find a way to do so without causing
interference to its customers, it neighbors and to those in foreign
countries.  

Please reject BPL technology until a different technology can
demonstrate an interference free method of transmission.

Thank you,

F. M. McDaniel III
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> -----Original Message-----
> From: Ray Andrews [mailto:[email protected]] 
> Sent: Wednesday, March 17, 2004 5:38 PM
> To: [email protected]
> Subject: [10m] BPL Comment Period Now Open
> 
> 
> I received the following notice from the ARRL Central 
> Division Director, Dick Isely, W9GIG:
> 
> =============================================
> 17 MAR, 2004 - 1215 CST
> 
> As some of you know, this sets the clock running for comments 
> to the NPRM of ET Docket 03-104 (BPL).
> 
> Federal Register: March 17, 2004 (Volume 69, Number 52). 
> The comment deadline is 45 days after publication, so appears 
> this would be May 1, which is a Saturday. I'm unsure if that 
> makes the Comment deadline Friday, April 30 or Monday, May 3.
> 
> --------------------------------------------------------------------
> ARRL Central Division
> Director: George Isely, W9GIG
> [email protected]<about:blank>
> 
> ==============================================
> 
> PLEASE take a few moments to file a comment on this NPRM 
> which poses the greatest possible threat to the future of HF 
> communications as we know it.
> 
> You may file a comment by going to the following URL:  
> http://gullfoss2.fcc.gov/ecfs/Upload/> <about:blank>
> 
> Check the 
> item labeled "Broadband Over Power 
> Line (BPL) - Docket 03-104" and click on "Continue". This 
> will take you to a form where you can enter your name & comment.
>  
> 73, 
>  
> Ray Andrews, K9DUR
> Assistant Central Division Director
>  
> 
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