[KYHAM] BPL Notice of Inquiry Comments Deadline

[Tim Anderson]

The deadline for filing comments in the Notice of Inquiry "Carrier Current
Systems, including Broadband over Power Line Systems" (ET Docket No. 03-104)
is July 7th.

I urge all Amateurs to make their voices heard on this serious issue.  It�s
not that BPL (Broadband Over Power Lines) also sometimes called PLC (Power
Line Communications) is an evil technology; on the contrary, it holds a
great deal of promise for providing reliable Internet access through means
other than the telephone and cable companies to locations not easily served
by these utilities.  The problem is, that in their de-regulatory, zeal to
promote it, the FCC appears to be ignoring the obvious and ominous technical
implications this technology could bring upon us unless due diligence is
observed.

There are two types of BPL being discussed.
BPL "Access" is a last-mile technology. Data is handed off from a
fiber-optic or T-1 line from the provider and injected into the
medium-voltage, local distribution lines. Some providers then use Wi-Fi
technology to go directly into homes, avoiding the step down transformers
and the low-voltage lines. A broadband connection then is accessed through a
Wi-Fi hookup in the home. Others either go around the transformer or through
it, sending IP packets onto the low-voltage lines and then directly to power
outlets. The connection is accessed via a standard HomePlug-certified device
that plugs into a wall.
"In-House" BPL uses existing electric utility wiring to network computers
and printers, as well as smart devices, within the building.
Both systems use carrier-current techniques with multiple carriers spread
over the frequency range of 2-80 MHz.  Early tests indicate BPL could raise
the noise floor +30 dB above galactic background at HF and the ARRL's
calculations estimate that the ambient noise level near PLC systems could
increase as much as 70 dB. Obviously this would render communications at
these frequencies (and their 2nd & 3rd harmonics!) useless.  Be assured that
power lines distributing this technology will radiate, as there is nothing
to stop it.

The proposal also opens the door for other unlicensed part 15 devices. Part
15 regulations, as they stand, prohibit the RF power injection levels
required for BPL and the resulting unintentional radiation.  A �relaxation�
of the Part 15 rules that would be required to accommodate BPL could be
applied to all Part 15 devices.  From light dimmers to computers, TVs and a
myriad of other every-day electronic devices, without strict emission
standards, manufacturers will simply let the RF hash fly.

"Right now with BPL/PLC, there are more questions than answers, and until
those questions are answered, these systems should not be widely deployed,"
said ARRL Lab Manager and RFI guru Ed Hare, W1RFI. "The time to raise and
answer these questions is now. I truly hope that the NOI will provide a
means for the FCC to do just that."

In its BPL inquiry, the FCC is seeking information, comment and technical
data that includes the current state of high-speed BPL technology; the
potential interference effects, if any, on authorized spectrum users; test
results from BPL experimental sites; and the appropriate measurement
procedure for testing emission characteristics for all types of carrier
current systems.

To file your comments:

1.	Go to this link: http://gullfoss2.fcc.gov/ecfs/Upload/

2.	Select "Broadband Over Power Line (BPL) - Docket 03-104"

3.	Then type in or paste your comments.


Below are the comments that I filed. If you agree with my comments, you can
use it simply by changing the signature lines, or compose your own from
scratch.  I urge you to comment.  For more information on BLP, go to:
http://www.arrl.org/tis/info/HTML/plc/

Thanks & 73

Tim Anderson - AG4XM
ARRL Technical Coordinator, KY Section
Editor, NKARC Feedline

=================================================

Dear Sirs/Madams,

This is in reply to the Notice of Inquiry # 03-104I

I am opposed to allowing Broadband over Power Lines (BPL) under the existing
Part 15 regulations. Future changes to part 15 that accommodate BPL, to the
detriment of the Amateur Radio Service as well as other licensed services,
must also be avoided.

BPL radiation from power lines, which cannot be contained, will seriously
hinder the Amateur Radio community and other licensed services that use the
HF spectrum and will add extreme technical difficulties for our Amateur
Radio Emergency Service. Further, interference to Amateur Radio Emergency
Services will place the public at risk in times of disaster and
communications emergencies. Routine and daily use of Amateur Radio by
definition is practice for said emergencies. Amateur Radio Operators have
made sizeable investments of time and money for licensing and equipment
whose performance will be severely degraded or rendered useless if BPL is
allowed to go forward.

It is of extreme importance that interference from BPL, verified by
well-known, published, test results in this country and others are
undertaken before any wide scale, commercial development of the technology
is begun. Other countries and NGO's here and abroad have found this BPL
scheme flawed. This scheme will render a major portion of the HF spectrum
unusable to conventional forms of communications.

Stringent enforcement of Part 15 regulations, as they stand, prohibits the
commercial implementation of BPL systems.  An amendment of Part 15 that
would allow BPL would also open the door to the manufacture of all-manner of
devices with unacceptable unintentional radiation characteristics further
compounding spectral interference to the detriment of the public-good.


I respectfully submit these comments for your consideration,

Timothy B. Anderson
Amateur Radio Station AG4XM
Technical Coordinator, ARRL KY Section
Broadcast Systems Engineer
Network Systems Engineer