I don't mean to bore you or overload you on the subject but this is very
serious. The ham radio community needs to take action. Here is additional
information and suggestions for response on the BPL subject.
Please take the time to read all the was through.
Thanks es 73
Bob, K4TAX
----- Original Message -----
From: "Charles S Osborne" <cosborne@pari.edu>
To: "Southeastern VHF Society" <svhfs@svhfs.org>
Sent: Monday, August 18, 2003 8:28 PM
Subject: SVHFS viewpoint on Broadband Over Power Lines
> There is still one day left for reply comments to the FCC NOI-BPL #03-104.
>
> I urge everyone to make some individual comments to the FCC. At this stage
> it is necessary to be filing "reply comments" only. Bert and I put
something
> together, which I filed last Friday night on behalf of SVHFS. It is at the
> end of this original message where Bert sent the links to ARRL and FCC
> appropriate pages.
>
> I hope this makes some points that stick with the FCC or echo and support
> other commenters. Sorry I didn't have time to make more concrete technical
> barbs, but perhaps the vague fear that there are some huge unseen dangers
> enforcement wise looming, interference well beyond the 2-80 MHz range, and
> International interference backlash, will keep this cat in the bag.
>
> I have to admit, this is likely one of the most widely commented NOI I've
> ever seen. And the number of engineering level warnings, should at least
say
> something. Its one thing to get lots of "You can't do this!" and "I don't
> think this is right." type comments. But very unusual to have this volume
of
> lengthy engineering analysis refuting the FCC position.
>
> 73,
> Charles S. Osborne, K4CSO
> Technical Director
>
> Pisgah Astronomical Research Institute
> 1 PARI Drive, HC 73, Box 638
> Rosman, NC 28772-9614
> http://www.pari.edu
> 828-862-5813 direct
> 828-862-5554 main
> 828-862-5877 FAX
> cosborne@pari.edu
>
> ----- Original Message -----
> From: "Bert Rollen - K4AR" <k4ar@arrl.net>
> To:
> Subject: SVHFS BOD viewpoint on BPL ?
>
>
> >
> > Gentlemen,
> >
> > Ed Hare, W1RFI, has posted an "unofficial" list of comments that makes
it
> > easier to find the ones from the major players.
> >
> >
>
<http://www.arrl.org/~ehare/rfi/plc/hyperlinks.html>http://www.arrl.org/~eha
> re/rfi/plc/hyperlinks.html
> >
> > *************************************
> >
> > WY6K has provided the following tips:
> >
> > How do we make comments to the FCC? Email or written? Addressee and
> > address?
> >
> > Several suggested I summarize how to do this:
> >
> > 1. Go to http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
> > 2. Enter only 03-104 in Box 1 (Proceeding).
> > 3. Complete all required boxes (2, 3, 7, 8, 9, 10 & 12)
> > 4. Attach your file in .doc, .pdf, .xls, etc in the first large
> > box and click "Sent Attached File to FCC".
> >
> > OR...and much easier for shorter comments,
> >
> > 5. Type your comments directly into the bottom large box,
> > keeping <70 characters per line, and click "Send Brief
> > Comments to FCC".
> >
> > After 4. or 5., another screen should appear where you need to
> > click "Finish Transaction and Receive Confirmation". If you
> > did everything correctly, you should then receive a confirmation
> > number on the next screen. If you don't see the confirmation
> > number, your comments were not submitted correctly.
> >
> > Your comments will likely not appear until the next
> > business day since it takes them awhile to process everything.
> > Please DO comment before the August 20 window closes! This
> > could be the most important thing you will ever do to insure we
> > do not allow the FCC fill our bands with interference. Let's prevent
> > another Pandora's Box like the FCC gave us with Citizens Band!
> >
> > 73, Bill W4ZV
> >
> > P.S. Much more info is available at ARRL's webpage:
> > http://www.arrl.org/tis/info/HTML/plc/ including how to file.
> >
> >
> >
> ---------------SVHFS Reply Comment #2003815105900 --------------
>
> Before the
>
> FEDERAL COMMUNICATIONS COMISSION
> Washington, DC 20554
>
>
> In the Matter of: )
> )
> Inquiry Regarding Carrier Current Systems, )
> Including Broadband Over Power Line ) ET Docket 03-104
> Systems )
>
> REPLY TO THE COMMENTS OF
> THE ALIANCE FOR PUBLIC TECHNOLOGY
> (DOCUMENT # 6514284392)
>
> August 12, 2003
>
> The Southeastern VHF Society (SVHFS) is pleased to reply to comments
filed
> regarding Broadband over Power-line Technology submitted by the Alliance
for
> Public Technology (APT). SVHFS is a not-for-profit organization comprised
of
> individuals from diverse backgrounds and occupations linked together via a
> common bond, that of furthering the state of the art of weak signal VHF
> through beyond microwave communications. SVHFS not only recognizes the
need
> for advanced telecommunications, our membership enables these advances
both
> through occupation and applied research into new digital technologies and
> propagation modes.
>
> While the SVHFS believes that the intentions of the Commission are fully
> directed toward the growth of broadband services resulting in more choices
> to consumers, SVHFS must take exception to the beliefs that BPL is a
premium
> opportunity to achieve these goals. SVHFS agrees with APT's self
assessment
> that they are not in a position to comment on technical questions raised
in
> the Notice, however, technical, engineering, and physics issues cannot be
> ignored or overlooked, regardless of best intentions to bring advanced
> services and applications to Americans. To do otherwise is simply
> irresponsible, and a waste of those very American's tax dollars.
>
> SVHFS commends the APT on their efforts now embodied in Section 706 of
the
> 1996 Act, however SVHFS will have to fundamentally disagree with the
> aggressiveness promoted in achieving these ends, with blatant disregard to
> technical issues and near certain impact to existing systems and services.
>
> SVHFS strongly disputes the APT assertion that Broadband over Power-Line
has
> the potential to become a strong facilities based provider in the
developing
> broad band marketplace, and rather is poised for disruption to existing
> services and facilities for the following reasons:
>
> 1. Digital signals, however conveyed, are inherently difficult to
restrict
> to their basic modulation bandwidths (in this case 2 to 80 MHz) and will
> cause harmful interference to services occupying the harmonic multiples of
> this range. We have often seen 5 MHz digital signals generate receivable
> energy well beyond 10 GHz via these harmonics. Low manufacturing cost
> targets are juxtaposed to the application of adequate filtering to control
> this problem.
>
> 2. Coupling of BPL signals to uncontrolled impedance unshielded lines is
in
> effect giving them an antenna. The effectiveness of this antenna is
> proportional to its length in wavelengths. Most typical power lines will
> provide multiple wavelength efficient radiators of this energy. In fact
> power lines will prove to be a lossy medium to convey the desired signal
to
> its intended destination because of this radiation.
>
> 3. These frequencies by nature are "International" in that very low power
> (milliwatts) can facilitate communications worldwide. By radiating in this
> range the BPL providers will become the targets of worldwide interference
> complaints. But being a non-licensed service, it is not readily traceable,
> except to the nation of origin. Japan has withdrawn their interest in this
> technology after realizing its potential for interference both locally and
> globally.
>
> 4. This technology while functional in limited tests, in our experience,
> will not "scale well". That means the deleterious effects will grow
> exponentially with broad deployment. Large areas will in effect become
more
> efficient phased array radiators of this noise.
>
> 5. Due to the efficiency of the power lines as antennas at these
> frequencies, reciprocity says they will also couple or receive existing
> services' RF power into the receivers of the BPL signals efficiently as
> well, in all likelyhood rendering them inoperative. This will cause
licensed
> users of this spectrum to become the targets of interference complaints
from
> unlicensed and less technically competent users. Our experience has seen
> this escalate to life threats with firearms over mere television
> interference complaints against operators working within the FCC rules,
and
> consumers violating the law with illegal cable television taps. Similar
> episodes are inevitable with BPL.
>
> 6. It has been our personal experience that power utilities have a
> horriffic record at correcting interference even from corona from damaged
> utility hardware at 60Hz. It is logical to assume, that when this
> interference problem covers millions of existing services' frequencies,
the
> FCC's challenges at enforcement will be unbelievable.
>
> While APT encourages the Commission to take action to bolster broadband
> competition, SVHFS encourages the Commission to take the opportunity to
> employ sound engineering practices (as is currently done by the Commission
> with similar radiated and conducted succeptability measurements) for the
> long term good of the American people. This should include maintaining
Part
> 15 limits at current levels or below.
>
> SVHFS agrees with APT that the Commission should regulate in a neutral
> manner, however, this should not preclude proper engineering assessment,
> consideration to shielding, and emission limits. It is our recommendation
> as engineers, experienced radio frequency designers, and users of
equipment
> for this spectrum, that the BPL technology is not field proven, and wholly
> inappropriate for the scope and breadth of application being suggested in
> this case.
>
>
> Respectfully submitted,
>
> H.Y. Rollen Jr.
> President
>
> C.S. Osborne
> Technical Chair
>
> Southeastern VHF Society, Inc.
> PO Box 1255
> Cornelia, GA 30531
>
>
>
>
> =========================================================
> Southeastern VHF Society Reflector
> svhfs@svhfs.org
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