On 28 Aug 2003 at 19:21, Steve Lawrence wrote:
> FYI - See the attached link for AMRAD's position. Chalk one up for
> using facts and data in assessing BPL.
>
> 73, Steve WB6RSE
>
> http://www.arrl.org/news/stories/2003/08/28/2/?nc=1
>
Amrad's FCC comments can be seen here:
http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_d
ocument=6514683575
AMRAD's reply comments seemed largely on target,
although I was a bit troubled by their statement on
page 2 about the present Part 15 rules. I would be the
first to acknowledge that Part 15 helps radio amateurs
more than it hurts them, in the sense that without the
rules, interference to hams today would be orders of
magnitude worse. I'm troubled, just the same, that
the way they phrased their comments early on in the
document amounts to a concession that there are
already 'acceptable' levels of interference and that their
best and fondest hopes are merely to influence the
FCC to not increase which amount of interference
will be deemed 'acceptable'. That strikes me as
somewhat of a 'pact with the devil'. There was much
similar debate in the past over federal government
regulations for the food-processing industry which allow
in general for acceptable levels of contamination to
packaged food products. This produced loud cries from
consumer advocates that our government is willing to
allow "acceptable levels of filth" in the food supply.
Reality informs us that it is actually very difficult,
perhaps near-impossible to achieve the goal of zero
contaminants. So far as I know, those accomodating
food regs remain in force to this day, despite past
controversy. In the balance of their document, AMRAD
makes the case for much more field and lab testing, and
that BPL deployment is truly a disaster in the making
for existing HF communicators and an enforcement
nightmare for FCC. BTW it also does not help that
several spelling and editing errors crept into the
AMRAD filing.
A big difference today, which AMRAD and others correctly
point out, is that even the present Part 15 rules will allow
oppressive levels of interference because of the
broadband nature of BPL. Unfortunately, AMRAD seems
to be trying to play it both ways in their filing. I fear that
BPL proponents will seize on the page 2 comments,
ignoring the full argument, which actually has it that present
Part 15 rules will already allow more than HF radio comms
can handle once they install what amounts to a diffuse,
broadband jamming transmitter system. Their comments are
otherwise quite constructive and they point out correctly that
it is not a trivial matter to fully or even partly characterize
the great potential for interference after BPL gets deployed
widely, that there is no present basis whatever for vague,
unsupported claims that BPL demonstrations are causing
no harmful interference at present and that full deployment
would not in the future.
Personally, I see the need to stress that much of HF
comms consist of weak-signal work. In that regard, ham
radio already suffers interference from digital consumer
devices which are already widely deployed. I think that
the vulnerability of weak-signal work cannot be over-
emphasized, and that is exactly what I told FCC.
On balance, I liked the PVRC filing better because it put
emphasis on the imminent demise of weak-signal work
on HF and went on to draw strong comparisons between
DXing/contesting and emergency HF comms, many
provided directly by hams in times of disaster. They also
pointed out that HF comms from an airliner over the middle
of the ocean might well be drowned out in the BPL din.
OK, some will say, there are still satellite comms in that
case. Well, that is not something we can definitely count
on. In times of large scale internationsl conflict, it is easy
to imagine scenarios where many satellites get destroyed
or crippled in attacks. What's left then? HF? Not a chance
if the power grid continues to function and BPL is widely
deployed. 73, K3KY
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