Thanks for your very thought provoking comments, Jim.
While I am not sure that I agree that large scale BPL
rollout is a fate accompli, I do agree that it is important
that reply comments address the regulatory challenges
and other possible untintended consequences that will
face the commission if they allow BPL rollout to go
forward. Based on their statements at the end of the
NOI, the commissioners all appear to have a "honeymoon"
attitude toward BPL. We need to make sure they look
at her without all the makeup.
73 de Mike, W4EF.........................................
> I'd also mention that all too many of those comments seem to be along the
> lines of
> "BPL will make HF unusable, don't do it"
>
> When the FCC has said that BPL is a done deal, and they're just looking
for
> advice on regulation/procedure for implementation.
>
> Here's my list of talking points:
> 1) FCC must weigh the public good of wider variety of access against
> degradation in service. Does BPL provide sufficient additional
capability,
> particularly in a non-trivial rollout (undergrounding of utilities makes
> access BPL kind of useless)
> 2) Part 15 kinds of limits is aimed at single consumer boxes stemming from
> EMI/EMC issues in the 70's. Are the style of the regulatory requirement
> philosophy of Part 15 appropriate to BPL (particularly the part carried on
> MV feeders).
> 2a) The part 15 philosophy is two pronged: EMI/EMC limits on mfred
> equipment is half; the other half is the responsibility of the equipment
> operator to mitigate interference.
>
> 3) There is a great diversity between the manufacturers, installers,
> owners, and users of BPL equipment. Who is responsible for finding and
> fixing interference? The ISP using the BPL channel? The company owning the
> BPL box? The power company which rents the usage of the wires to the BPL
> box owner? etc. There is a mix of regulated and unregulated entities
here,
> and there are economic incentives to point the finger "somewhere else".
>
> 4) This is not a point source of interference, and identifying the source
> is difficult:
> a) Line source
> b) low frequency so DF doesn't work like it does at VHF/UHF
> c) The emission is broad band and noise like, not a narrow tone (unlike
the
> "wireless modem hookup, which was narrow band in the 80m band), making it
> difficult to detect (total power radiometers?)
> d) large scale deployment makes it worse
>
> 5) unforeseen effects
> a) skywave propagation (international treaty obligations, etc.)
> b) intermodulation (among various BPL signal components) from weathered
> equipment, e.g., could produce "out of band" or spurious signals that are
> hard to localize
>
> 6) Has testing adequately assessed the impact of the aging physical plant
> on the viability of BPL as a legitimate competitor (since the FCC's
mandate
> is to foster competition).
> a) Corroded wire, semiconductive insulation reduces effectiveness of wires
> as transmission line
> b) Does the economic plan address the gradual undergrounding of utilities.
> c) Are there more competitive alternatives available (i.e. the replacement
> of cables with fiber optic cored cabling, as currently used on HV
> transmission lines)
>
> 7) Safety aspects
> a) You've got to couple across the galvanic barrier of the distribution
> transformer.
>
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